In Brief
This case involved review petitions filed by the Government of Delhi and Delhi Development Authority challenging orders dismissing their appeals on land acquisition matters. The appeals had been dismissed based on Pune Municipal Corporation v. Harakchand Misirimal Solanki, which was later overruled by a Constitution Bench in Indore Development Authority v. Manohar Lal. The majority allowed the review petitions, holding that overruling of the foundational precedent by a larger bench, combined with liberty reserved in an earlier decision, warranted review in the public interest. The dissent argued that overruling affects only precedential value, not finality of decrees between parties, and that the Explanation to Order 47 Rule 1 CPC bars such reviews, as allowing them would undermine judgment finality and spawn endless litigation.
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