In Brief
A developer and its assignee appealed the High Court's order that had allowed a plaintiff's suit challenging a compromise decree. The Supreme Court held that an independent suit to set aside a compromise decree is barred under Order XXIII Rule 3A CPC. The plaintiff cannot circumvent this bar through clever drafting by seeking multiple reliefs (title, possession, cancellation of revocation, etc.) that ultimately depend on invalidating the compromise. The only remedy to challenge a compromise decree is through an application before the court that recorded it. The Trial Court's rejection of the plaint as unmaintainable was upheld; the High Court erred in entering into the merits of the decree's validity under Order XXXII Rule 7 CPC.
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