In Brief
Sathyanath challenged a High Court order remanding his case to the trial court to decide the res judicata plea as a preliminary issue. The Supreme Court held that the amended Order XIV Rule 2 of the Code mandates that courts pronounce judgment on all issues. While courts may decide preliminary issues relating only to jurisdiction or statutory bars, res judicata is a mixed question of law and fact that depends on pleadings and circumstances. Therefore, it cannot be decided as a preliminary issue. The Court set aside the High Court's order and directed the trial court to record findings on all issues to avoid remands and ensure expeditious disposal of the suit.
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