Introduction:

In a significant ruling, the Supreme Court of India in the case of M/S Faime Makers Pvt. Ltd. v. District Deputy Registrar, Co-Operative Societies (3), Mumbai & Ors. (2025 LiveLaw (SC) 379) addressed the applicability of the doctrine of res judicata to quasi-judicial bodies. The bench, comprising Justices Vikram Nath and Prasanna B. Varale, set aside the Rajasthan High Court’s decision that had upheld a second order by a quasi-judicial authority, despite an earlier unchallenged order on the same issue.

Background of the Case:

The dispute originated when M/S Faime Makers Pvt. Ltd. (the petitioner) contested an order by the District Deputy Registrar, Co-Operative Societies (3), Mumbai (the respondent). The respondent had granted unilateral deemed conveyance of certain leasehold rights and properties to Prakash Apartment Co-Operative Housing Society Ltd. (Respondent No. 2). This conveyance was based on a second application, even though a prior order on the same matter had attained finality and remained unchallenged.

Petitioner’s Arguments:

The petitioner, represented by Senior Advocate Mr. Dama Seshadri Naidu, contended that:

Violation of Res Judicata: The quasi-judicial authority’s second order contravened the principle of res judicata, which prevents re-litigation of issues already settled.

Lack of Jurisdiction: Once an order has attained finality, the competent authority lacks jurisdiction to entertain a subsequent application on the same issue.

Judicial Precedents: Reliance was placed on the Supreme Court’s decision in Ujjam Bai v. State of U.P., which affirmed that res judicata applies to quasi-judicial bodies.

Respondents’ Arguments:

The respondents, represented by Advocate Mr. Piyush Dwivedi and others, argued that:

Justification for Second Order: The second order was justified based on new circumstances or information that warranted reconsideration.

Authority’s Discretion: The quasi-judicial authority possessed the discretion to review and modify its decisions if deemed necessary.

No Finality in First Order: The initial order did not attain absolute finality, allowing room for re-examination.

Supreme Court’s Judgment:

Justice Vikram Nath, delivering the judgment, emphasized:

Binding Nature of Res Judicata: The principle of res judicata applies to quasi-judicial authorities, preventing them from reconsidering issues already settled.

Finality of Decisions: Once an order is accepted by parties and remains unchallenged, it attains finality, barring subsequent applications on the same matter.

Precedents Affirmed: The Court referenced Abdul Kuddus v. Union of India (2019) to reinforce that decisions by tribunals or authorities operate as res judicata.

The Court concluded that the second application should have been dismissed, and the High Court erred in upholding the quasi-judicial body’s second order. Consequently, the appeal was allowed, reinforcing the doctrine’s applicability to quasi-judicial proceedings.