Principle of Res Judicata Applies Between Two Stages of Same Litigation: Supreme Court

The Supreme Court held that the principle of res judicata applies between different stages of the same litigation, operating as "interlocutory res judicata."

The Bench ruled that the dismissal of an initial application to reject a plaint under Order VII Rule 11 of the CPC bars a subsequent application on the same substantive ground.

The Court clarified that it is immaterial if a different defendant files the subsequent plea, provided they share a common interest and defend the same title.

Parties cannot bypass the finality of a prior judicial order by reframing the same challenge under alternate procedural sub-clauses.

[B.S. Lalitha & Ors. v. Bhuvanesh & Ors.]