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Supreme Court of India 2022-01-18 allowed

Mamtaz & Ors vs Gulsuma Alias Kulusuma

Bench: 2 — M.R. Shah, Sanjiv Khanna

In Brief

The Supreme Court clarified the proper appellate procedure when a second appeal challenges a First Appellate Court's order dismissing an appeal on limitation grounds. A trial court had issued an ex parte decree; the defendant appealed late without condoning delay, so the First Appellate Court dismissed the appeal. The High Court then set aside both the First Appellate Court's order and the trial court's judgment itself. The Supreme Court held this exceeded the High Court's jurisdiction. The correct procedure is: the High Court should only set aside the dismissal order and remand to the First Appellate Court to decide condonation of delay and, if granted, the appeal on merits. The Court permitted revival of the withdrawn condonation application.

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Civil Procedure Limitation and Delay Ex parte Decrees Appellate Procedure Condonation of Delay

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