In Brief
The Union of India sought to resume land under an Old Grant tenure. The property holder, Vijay Krishna Uniyal, filed a suit for permanent injunction claiming ownership through a registered sale deed. The trial court and first appellate court found the land belonged to the Government and Uniyal held only occupancy rights. The High Court dismissed the second appeal as devoid of merit but made observations suggesting the sale deed showed prima facie evidence of Uniyal's ownership and granted liberty to raise the title issue in future eviction proceedings. The Supreme Court held that once title has been directly and substantially adjudicated and decided against a party, it operates as res judicata and cannot be reopened in collateral proceedings. The High Court's observations were improper and were set aside.
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