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1. ISSUES PRESENTED and CONSIDERED
The core legal issues considered in this case include:
2. ISSUE-WISE DETAILED ANALYSIS Issue 1: Res Judicata and Suit No. 5 of 1978 The appellants argued that the findings in Suit No. 5 of 1978 should be considered res judicata since no appeal was filed against it. The Court examined Section 11 of the Civil Procedure Code (CPC), which outlines the doctrine of res judicata, emphasizing that a matter is directly and substantially in issue if it is necessary for the decision of the case. The Court referenced precedents, including Sajjadanashin Sayed and Tamil Nadu Wakf Board, to interpret what constitutes "directly and substantially in issue." It concluded that since the defendants had conceded not to evict the plaintiff forcibly, the trial court should have dismissed the suit without delving into the title issue, thus the principle of res judicata did not apply to the title issue. Issue 2: Nature of the Temple Property and Statutory Permission The trial court had determined the temple to be a private entity, not requiring statutory permission for property sale. However, the High Court reversed this, declaring it a public temple, thus requiring permission for alienation. The Court explored the implications of this reversal, considering whether the trial court's findings were necessary for the suit's resolution. Issue 3: Alteration of Findings Across Suits The Court addressed whether findings in Suit No. 5 of 1978 could be altered in an appeal from Suit No. 6 of 1978. The appellants argued that the High Court erred in modifying findings from a suit not under appeal. The Court considered the principle that a finding becomes final if no appeal is filed, as established in Premier Tyres Limited and Badri Narayan Singh. Issue 4: Doctrine of Res Judicata The doctrine's applicability was debated, focusing on whether the findings on the temple's nature and title were directly and substantially in issue. The Court emphasized the doctrine's importance in ensuring finality in litigation, referencing historical and international jurisprudence to underscore its significance. 3. SIGNIFICANT HOLDINGS The Court was divided, with Justice Katju dismissing the appeal, emphasizing that the trial court's decision on the title was unnecessary and thus not subject to res judicata. Justice Ganguly dissented, arguing for the appeal's allowance, asserting that the findings on title were directly in issue and should be binding without an appeal. Justice Katju's Reasoning: "Once the defendants had conceded that they were not going to forcibly evict the plaintiff-respondents, then the suit should have been straightway dismissed on this ground alone, and it was not necessary for the trial court to have gone into any other issue, including the issue of title." Justice Ganguly's Reasoning: "The question of title of the trustees was prominently raised... unless a decision on this aspect and the title of the trustees is rendered, the further decision, namely, the dismissal of the suit cannot be reached." Core Principles Established:
Final Determinations: In light of the divergent opinions, the matter was directed to be placed before another bench for resolution, highlighting the complexity and significance of the issues involved.
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