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Supreme Court of India 2021-12-03 allowed

M.P. Housing and Infrastructure Development Board & Anr vs K.P. Dwivedi

Bench: 2 — M.R. Shah

In Brief

The MP Housing Board contracted with a developer to construct houses. Disputes arose; the developer filed a writ petition seeking to continue work. The High Court, with the consent of both parties, referred the dispute to the Housing Commissioner as arbitrator. The Commissioner passed an award rejecting the developer's claims. Without challenging this award, the developer later filed a new reference before the MP Arbitration Tribunal raising identical claims. The Tribunal dismissed this as not maintainable; the High Court reversed this. The Supreme Court restored the Tribunal's order, holding that once an arbitral award achieves finality by not being challenged, the same claims cannot be re-litigated before another forum. The principle of issue estoppel prevents parties from pursuing identical claims in successive proceedings.", <parameter name="cited_cases">[{"raw_citation": "(2018) 10 SCC 826", "case_name": "Madhya Pradesh Rural Road Development Authority and Another v. L.G. Chaudhary Engineers and Contractors", "cited_year": "2018", "paragraph": "6.5", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(1999) 5 SCC 590", "case_name": "Hope Plantations Ltd. v. Taluk Land Board, Peermade and Another", "cited_year": "1999", "paragraph": "6.6", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2005) 1 SCC 787", "case_name": "Bhanu Kumar Jain v. Archana Kumar and Another", "cited_year": "2005", "paragraph": "6.6", "treatment": "followed", "treatment_by": "this_court", "treatment_quote": "In the case of Bhanu Kumar Jain (supra) it is observed and held that a cause of action estoppel arises where in two different proceedings identical issues are raised, in which event, the latter proceedings between the same parties shall be dealt with similarly as was done in the previous proceedings."}, {"raw_citation": "(2006) 5 SCC 566", "case_name": "Pushpa Devi Bhagat (D) Th. LR. Sadhna Rai (Smt.) v. Rajinder Singh & Ors.", "cited_year": "2006", "paragraph": "6.7", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2004) 1 SCC 287", "case_name": "Rafique Bibi (Dead) By Lrs. v. Sayed Waliuddin (Dead) by LRs and others", "cited_year": "2004", "paragraph": "6.7", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2012) 3 SCC 495", "case_name": "M.P. Rural Road Development Authority and Anr. v. L.G. Chaudhary Engineers & Contractors", "cited_year": "2012", "paragraph": "8.2", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "(2019) 17 SCC 82", "case_name": "Hindustan Zinc Ltd. v. Ajmer Vidyut Vitran Nigam Ltd.", "cited_year": "2019", "paragraph": "8.6", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "AA No. 14 of 2017", "case_name": "Viva Highways Ltd. v. MP Rural Road Development Corporation Ltd.", "cited_year": "2017", "paragraph": "8.3", "treatment": "referred", "treatment_by": "this_court"}, {"raw_citation": "Civil Appeal No.4250 of 2018", "case_name": "M/s Essel Infra Projects Ltd. v. The State of MP", "cited_year": "2018", "paragraph": "8.3", "treatment": "referred", "treatment_by": "this_court"}]

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