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Supreme Court of India 2023-07-05 disposed

S. NARAHARI & ORS vs S.R. KUMAR & ORS

Bench: 2 — Krishna Murari, Sanjay Karol

In Brief

This case concerns the maintainability of a Special Leave Petition filed after the Supreme Court dismissed an earlier petition as withdrawn and granted liberty to approach the High Court for review. The core issue is whether this liberty automatically allows a subsequent Supreme Court petition. The bench found conflicting precedent: established cases require explicit permission for a fresh petition, but the Khoday Distilleries judgment suggests that non-speaking dismissals do not bind subsequent proceedings. Given this tension, the court referred the matter to a larger bench to clarify the law and prevent either endless litigation or arbitrary exclusion of remedies.

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Constitutional Law Civil Procedure Appellate Jurisdiction Special Leave Petition Judicial Review Merger Doctrine

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