Breaking SUPREME COURT REAFFIRMS PUBLIC DOMAIN PROTECTION FOR DIGITAL LAWS
New Delhi · Sunday, 20 September 2026 9888666310 | [email protected]
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Supreme Court of India 2017-02-21 partly_allowed

Jayantilal Chimanlal Patel vs Vadilal Purushottamdas Patel

Bench: 3 — Dipak Misra

In Brief

A landlord sought to evict a tenant for unauthorized construction of permanent structures on the rented premises. The earlier suit for injunction was dismissed based on Order 2 Rule 2 of the Code of Civil Procedure (res judicata principle). The Supreme Court held that to invoke Order 2 Rule 2, the defendant must prove the previous suit's plaint on record through evidence—not infer it. Since the prior plaint was not proved, that bar could not apply. The Court remitted the eviction suit to the High Court to decide the substantive merits: whether the tenant had erected structures without consent, as required by the Rent Control Act.

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Civil Procedure Res Judicata / Order 2 Rule 2 Landlord and Tenant Law Eviction Injunction

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