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Case Number

Civil Revision Petition (PD) No. 625 of 2004

Attorney(S)

Mr. S. Sounthar
For petitioner: Mr. Srinath Sridean
Respondents 6 to 24 given up.

Judges

K. Raviraja Pandian, J.

Acts

ARTICLE 227 CONSTITUTION OF INDIA

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Smart Summary

Structured Summary of the Opinion (Article 227 Revision)

Factual and Procedural Background

The revision petitioner invoked the jurisdiction of the High Court under Article 227 of the Constitution of India seeking to strike off the plaint in O.S. No. 20 of 2004 pending before the District Munsif Court, Karaikal.

The factual matrix described in the opinion is:

Respondents 1 to 5 instituted O.S. No. 20 of 2004 seeking permanent and mandatory injunctions restraining the 20th defendant (the revision petitioner) from making or continuing construction on the suit property and directing removal of any construction during the pendency of the suit.
Earlier, the respondents had filed O.S. No. 116 of 1998 against one Sivasubramanian and others claiming relief in respect of 180 kuzhies of Manaikattu together with various structures. The trial Court decreed relief for 100 kuzhies. On appeal, the decree was modified to 136 kuzhies, but in second appeals the trial Court’s decree (100 kuzhies) was restored by judgment dated 01.09.1998.
The revision petitioner is a subsequent purchaser of a portion of the property that was subject-matter of the earlier litigation. He contends that the present suit erroneously claims relief over an extent for which injunction was not granted earlier, thereby constituting an abuse of process and being barred by res judicata.
The High Court heard arguments, reviewed records and various authorities, and ultimately dismissed the revision.

Legal Issues Presented

Whether the plaint in O.S. No. 20 of 2004 ought to be struck off as an abuse of the process of law and/or as being barred by res judicata in light of the earlier litigation concerning substantially the same property.
Whether the High Court should exercise its extraordinary supervisory jurisdiction under Article 227 of the Constitution to strike off the plaint at the threshold, or whether the petitioner should be relegated to defend the suit before the trial Court or pursue ordinary remedies (e.g., application under the Code of Civil Procedure, appeal or revision).
Whether the facts of this case fall within the narrow and exceptional circumstances in which Article 227 may be exercised to terminate proceedings summarily (for example, when there is collusion, vexatious litigation, or a manifest, grave dereliction of duty by the subordinate Court).

Arguments of the Parties

Petitioner's Arguments

The respondents earlier litigated the relevant land and a decree was ultimately restored in the second appeal in favour of the respondents only to the extent of 100 kuzhies; the decree confirmed that the vendors (defendants in the earlier suit) had rights over 60 kuzhies and 20 kuzhies belonged to nobody (as per some observations in the earlier judgment).
On that basis, the petitioner (a subsequent purchaser) contended that the present suit improperly includes the extent for which injunction was not granted and thus is an abuse of process and hit by res judicata; consequently the plaint should be struck off.
The petitioner relied on several authorities (both local high court decisions and foreign law) to support the proposition that the High Court may strike off a plaint under Article 227 in appropriate circumstances.

Respondents' Arguments

The opinion does not contain a detailed account of the respondents' legal arguments opposing the revision other than the fact that they instituted O.S. No. 20 of 2004 seeking injunctions in respect of the suit property.

Table of Precedents Cited

Precedent	Rule or Principle Cited For	Application by the Court in This Opinion
Waryam Singh v. Amarnath, AIR 1954 SC 215	The power of superintendence under Article 227 must be exercised sparingly and only in appropriate cases to keep subordinate Courts within the bounds of their authority and not for correcting mere errors.	The Court relied on this principle to emphasise that Article 227 is to be invoked only in exceptional circumstances and not as a substitute for appeal or revision.
Nagendra Nath Bora v. Commissioner of Hills Division, AIR 1958 SC 398	Reiterates the limited scope of Article 227 and the sparing exercise of supervisory jurisdiction.	Used to support the general proposition that supervisory jurisdiction is limited and not intended to correct every error of subordinate Courts.
Bathutmal Raichand Owal v. Laxmibai R. Tarta, (1975) 1 SCC 858	High Court cannot, under the garb of Article 227, convert itself into a Court of appeal where Legislature has not provided a right of appeal.	Cited to reinforce that Article 227 should not be used to re-appreciate evidence or substitute decisions of the trial Court, except in the limited situations recognized by law.
R. v. Northumberland Compensation Appeal Tribunal, Ex Parte Shaw, (1952) All ER 122	Referenced in the course of explaining limits on supervisory powers (context provided via later Indian authorities).	Referred to as part of the jurisprudential background explaining constraints on supervisory jurisdiction; no direct factual application to this case.
Chandravarkar Sita Ratna Rao v. Ashalata S. Guram, (1986) 4 SCC 447	High Court in Article 227 may go into facts or evidence if justice so requires—where there is misdirection in law or a view of fact taken in the teeth of preponderance of evidence; decline to exercise jurisdiction where question depends on appreciation of evidence unless findings are perverse.	The Court applied this as a controlling principle to decline interference because the issues raised depended on appreciation of evidence and there was no finding of perversity or manifest injustice by the trial Court.
Trimbak Gangadhar Telang v. Ramchandra Ganesh Bhide, (1977) 2 SCC 437	High Court should not interfere with findings within the jurisdiction of inferior tribunal except where findings are perverse or not based on any material evidence resulting in manifest injustice.	Used to show that mere erroneous findings do not justify Article 227 interference; no such perversity was found here.
Ouseph Mathai v. Abdul Khadir, (2002) 1 SCC 319	Describes the limited extent to which High Court may exercise supervisory jurisdiction under Article 227.	Referred to as part of the line of authorities circumscribing Article 227; reinforced the view to restrict High Court intervention.
State v. Navjot Sandhu, (2003) 6 SCC 641	The High Court has power of superintendence, but that power should not be exercised in appreciation of evidence.	Cited to support the proposition that Article 227 should not be used to re-appreciate evidence; applicable in deciding not to strike off the plaint on the basis of disputed factual questions.
Rani Mohanraj v. P. Rajarathinam, 1999 2 LW 757	Example where plaint was struck off under Article 227 because the suit was vexatious and had no chance of success in the peculiar facts of that case.	The Court examined this decision, described its peculiar facts and concluded that those exceptional circumstances were materially different from the present case and thus it did not advance the petitioner’s case.
S. Viswanathan v. Sri Muruga Agencies, 2002 (1) TLNJ 13	Example where deliberate collusion and abuse of process (chief tenant and sub-tenant playing hide-and-seek) warranted striking off the plaint under Article 227 as an exceptional case.	The Court acknowledged it as an exceptional case but found the facts distinguishable and therefore not helpful to the petitioner.
K.K. Swaminathan v. Srinivasagam, 2004 1 LW 250	Case where a subsequent suit seeking to re-litigate an issue (e.g., genuineness of a promissory note) affirmed in the earlier second appeal was held to be an abuse of process and the plaint was struck off.	The Court examined the case and observed that its facts (direct re-litigation of an issue already finally determined) differ from the present dispute; it did not warrant striking off the plaint here.
Hunter v. Chief Constable of West Midlands, (1981) 3 All ER 727	English authority where a civil action was regarded as an abuse of process because the identical allegation had already been negatived in criminal proceedings culminating in conviction.	Cited by the petitioner, but the Court held that the facts of Hunter were materially different and therefore it did not assist the petitioner’s case.

Court's Reasoning and Analysis

The High Court proceeded by first outlining the legal scope and constitutional character of Article 227:

Article 227 confers on every High Court a power of superintendence over subordinate Courts and tribunals; this power is both administrative and judicial and is extraordinary and discretionary (not a matter of right to litigants).
The supervisory jurisdiction is not an appellate or revisional jurisdiction; it must be exercised sparingly and only in appropriate and exceptional cases, particularly where there is grave dereliction of duty, flagrant abuse of power or manifest injustice attributable to the subordinate Court.
The High Court must have regard to legislative policy and the availability of efficacious alternative remedies—if adequate alternative remedies (such as defense of the suit, applications in the trial Court, appeal or revision) are available, supervisory jurisdiction should ordinarily be declined.
The High Court should not re-appreciate evidence under Article 227 except in limited circumstances (misdirection in law, view of fact taken in the teeth of preponderant evidence, perversity, or manifest injustice).

Applying these principles to the facts, the Court analyzed the petitioner's contentions and the precedents relied upon:

The Court examined the earlier litigation and records which showed that an injunction decree had been granted only in respect of 100 kuzhies; the petitioner argued res judicata and that the present suit improperly claimed relief beyond that extent.
The Court found that the cited authorities (both local and foreign) exemplified exceptional factual situations — vexatious litigation, collusion, direct re-litigation of issues already finally determined, or where criminal proceedings had negatived the same allegation — and that those facts were materially different from the present case.
The Court held that the trial Court had not committed any manifest error warranting the exercise of Article 227; the only specific action identified was the issuance of summons to defendants, which in itself did not amount to a transgression of jurisdiction or an abuse justifying summary striking off of the plaint.
The High Court emphasized that if the petitioner believed the plaint should be struck off, he could and should place the relevant materials before the trial Court and seek relief there (for example, by an application under the Code of Civil Procedure), or pursue ordinary appellate or revisional remedies where available.
The Court also observed the institutional context — High Courts are burdened with heavy backlogs — and cautioned litigants to approach courts of first instance first rather than seeking summary intervention by the High Court in matters that properly fall for adjudication at the trial level.

Because the issues raised involved disputed factual questions and because the trial Court had not been shown to have committed a grave or manifest error or to have acted in abuse of its jurisdiction, the Court declined to exercise its extraordinary jurisdiction under Article 227.

Holding and Implications

Final Holding: The revision is dismissed.

Direct consequences and instructions given by the Court:

The petitioner is relegated to seek appropriate relief before the trial Court (for example, an application to strike off the plaint under the Code of Civil Procedure or other suitable remedy) and may also pursue any other statutory remedy available to him.
The trial Court, if approached by the petitioner, shall dispose of any application in accordance with law and shall not be influenced by any observations made in the High Court's order.
No costs were awarded.

Broader implications:

The decision reiterates the established principle that Article 227 is extraordinary, to be exercised sparingly and not as a substitute for ordinary remedies; the Court expressly found no reason to lay down a new precedent and confined its order to the facts of the petition before it.
The Court issued a cautionary note to litigants to approach the trial Court first and avoid premature recourse to the High Court, especially in light of institutional backlog — but the opinion did not purport to create any novel legal test or depart from established doctrine on Article 227.

VCJ/VCS

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Ganapathy Subramanian Petitioner v. S. Ramalingam & 23 Others S

This revision is filed invoking the jurisdiction of this Court under Article 227 of the Constitution of India to strike off the plaint in O.S No. 20 of 2004 on the file of the District Munsif Court, Karaikal, Pondicherry.

2. The case of the petitioner is that respondents 1 to 5 filed a suit in O.S No. 20 of 2004 on the file of the District Munsif, Karaikal, seeking for permanent injunction against the 20th defendant, who is the revision petitioner, restraining him from making or continuing with any construction in any part of the suit property with the collusion and connivance of the other 19 defendants either by himself or through his men and for a mandatory injunction against the petitioner directing him to remove any construction made or to be made by him during the pendency of the suit.

3. It is the pointed case of the petitioner that the said respondents earlier filed a suit in O.S No. 116 of 1998 on the file of the District Munsif Court, Karaikkal against one Sivasubramanian and three others seeking for a decree for permanent injunction restraining the defendants therein from interfering with the peaceful possession and enjoyment of the suit property in that case. The suit property in respect of which relief was claimed in that case was 180 kuzhies of Manaikattu with a building bearing municipal door No. 66/1, with the bio gas plant and standing trees manure pit, cattle shed etc. The trial court decreed the suit for an extent of 100 kuzhies only. On appeal in A.S No. 45 of 1993, the decree was modified by declaring that the plaintiffs were entitled to a decree in respect of 136 kuzhies of land. Two second appeals were filed by the respective parties in S.A Nos. 1017 and 1224 of 1996 against that order. By judgment dated 01.09.1998, the decree of the trial Court was restored in the second appeal. The petitioner is the purchaser of the property which was a portion of the subject matter of the suit property. Now, the respondents/plaintiffs, on an erroneous view of the matter, filed the present suit including the extent for which injunction decree has not been granted in the earlier round of litigation by arraying the legal representatives of the deceased Subramanian along with the petitioners. Hence, the present revision is filed by the subsequent purchaser, the 20th defendant invoking Article 227 of the Constitution of India contending that the present suit is abuse of process of law and the suit should not have been taken on file.

4. It is the contention of the learned counsel for the petitioner that originally, the trial Court granted a decree only in respect of 100 kuzhies in favour of the respondents and recorded a finding that the defendants therein who were the vendors of the petitioner/20th defendant are having a right over the suit property over an extent of 60 kuzhies and remaining 20 kuzhies belong to nobody, which decree has been confirmed by this Court in the second appeal. Hence, the suit has to be rejected by this Court as abuse of process of law, and the suit is hit by res judicata. The learned counsel also relied upon the judgments in the cases of Rani Mohanraj v. P. Rajarathinam, 1999 2 LW 757; S. Viswanathan v. Sri Muruga Agencies, 2002 (1) TLNJ 13 = 2002 2 L.W 243; K.K. Swaminathan v. Srinivasagam, 2004 1 LW 250; and Hunter v. Chief Constable of West Midlands, (1981) 3 All ER 727, to bring home his contention that the suit has to be rejected.

5. Heard the learned counsel for the petitioner and perused the materials available on record.

6. Article 227 of the Constitution of India confers on every High Court the power of superintendence over all Courts and Tribunals through out the territory in relation to which it exercises jurisdiction excepting any Court or tribunal constituted by or under any law relating to the armed forces. Without prejudice to the generality of such power, the High Court has been conferred with certain specific powers under clauses (2) and (3) of Article 227 of the Constitution. It could be seen that the power of superintendence so conferred on the High Court is administrative as well as judicial and is capable of being invoked at the instance of any person aggrieved. The paramount consideration behind vesting such wide power of superintendence in the High Court is to clear the path of justice. Such a power of superintendence is not subject to technicalities of procedure or traditional fetters. That power so conferred cannot also be regarded as appeal or revisional jurisdiction and should not be exercised in the garb of exercise of supervisory jurisdiction under Article 227 of the Constitution and hence, the Court has devised a self imposed rule of discipline on this power. The supervisory jurisdiction can be refused to be exercised when an alternative efficacious remedy by way of defending the suit or filing an appeal or revision is available to the person aggrieved. The Court shall have regard to the legislative policy formulated on experience and expressed by enactments where the legislature in exercise of its wisdom has deliberately chosen certain orders and proceedings to be kept away from the appellate or revisional jurisdiction in the hope of accelerating conclusion of the proceedings and avoiding delay and procrastination which is occasioned by subjecting every order at every stage of proceedings to judicial review by way of appeal or revision.

7. It is not denied that the powers conferred upon the High Court under Article 227 of the Constitution of India are extraordinary and discretionary power as distinguished from ordinary statutory power. No doubt, Article 227 of the Constitution conferred a right of superintendence over all Courts and Tribunals throughout the territories in relation to which it exercised jurisdiction, but no corresponding right is conferred upon the litigant to invoke the jurisdiction as a matter of right. In fact, the power under Article 227 of the Constitution of India casts a duty upon the High Court to keep the inferior Courts and tribunals within the limits of its authority and that they do not cross the limit ensuring the performance of their duties in accordance with law conferring power within the ambit of the enactment treating such Court and Tribunals. Only wrong decisions may not be a ground for the exercise of jurisdiction under this article unless the wrong is referable to grave dereliction of duty and flagrant abuse of power by the subordinate courts and tribunals resulting in grave injustice to any party.

8. In Waryam Singh v. Amarnath, AIR 1954 SC 215, the Supreme Court has held that the power of superintendence conferred by Article 227 of the Constitution has to be exercised most sparingly and only in appropriate cases in order to keep the subordinate Courts within the bounds of their authority and not for correcting mere errors. This position of law has been reiterated in the case of Nagendra Nath Bora v. Commissioner of Hills Division, AIR 1958 SC 398; and in Bathutmal Raichand Owal v. Laxmibai R. Tarta (1975) 1 SCC 858, wherein it was held that the High Court cannot in guise of exercising its jurisdiction under Article 227 of the Constitution, convert itself into a Court of appeal, when the Legislature has not conferred a right of appeal. After referring to the judgment in the case of R. v. Northumberland Compensation Appeal Tribunal, Ex Parte Shaw, (1952) All ER 122; the Supreme Court in the case of Chandravarkar Sita Ratna Rao v. Ashalata S. Guram, (1986) 4 SCC 447, held that it is true that in exercise of jurisdiction under Article 227 of the Constitution, the High Court could go into the question of facts or look into the evidence if justice so requires it, if there is any misdirection in law or a view of fact taken in the teeth of preponderance of evidence. But the High Court should decline to exercise its jurisdiction under Articles 226 and 227 of the Constitution to look into the fact in the absence of clear and cut-down reasons where the question depends upon the appreciation of evidence. The High Court also should not interfere with a finding within the jurisdiction of the inferior tribunal except where the findings are perverse and not based on any material evidence or it resulted in manifest injustice (see Trimbak Gangadhar Telang v. Ramchandra Ganesh Bhide, (1977) 2 SCC 437). Except to the limited extent indicated above, the High Court has no jurisdiction, vide Ouseph Mathai v. Abdul Khadir, (2002) 1 SCC 319. It was also held by the Supreme Court in the case of State v. Navjot Sandhu, (2003) 6 SCC 641 that though the High Court has power of superintendence and that power should not exercised in appreciation of evidence.

9. By the above exposition of law ruled by the Supreme Court, the scope and amplitude and the power of the High court in invoking Article 227 of the Constitution of India has been made crystal clear.

10. As already stated, learned counsel for the petitioner relied upon the decisions in the cases of Rani Mohanraj v. P. Rajarathinam, 1999 2 LW 757; S. Viswanathan v. Sri Muruga Agencies, 2002 (1) TLNJ 13; K.K. Swaminathan v. Srinivasagam, 2004 1 LW 250; and Hunter v. Chief Constable of West Midlands, (1981) 3 All ER 727 in support of his contentions.

11. The facts of the case in Rani Mohanraj v. P. Rajarathinam, 1999 2 LW 757 is that one Mohanraj died on 23.11.1997 He had a minor daughter by name one Varsha Dhanasri. The brother of the deceased Mohanraj filed a Guardian OP to declare him as the guardian of minor Dhanasri and to have custody of the property of the deceased Mohanraj, who bequeathed under his will, to his minor daughter, against Mohanram's wife and her father. The brother also moved an application for interim injunction restraining the mother of the minor daughter and the parents of the mother from interfering with the possession of the property. Ad interim injunction was also granted. That order was carried on by way of revision by the mother challenging the locus standi of Rajarathinam in filing the OP and also getting him appointed as a guardian, when the natural guardian is alive. That order of interim injunction was set aside by this Court in the revision and further, the lower Court was directed to pass orders about maintaining the guardian OP and further directed the trial Court to decide on the question on the territorial jurisdiction before entertaining that application. In pursuance of the direction issued by this Court, the trial Court dismissed the OP. Yet another factor is that the mother filed two complaints before the Commissioner of Police - one prior and another subsequent to the order passed by this Court in the revision to the effect that Rajarathinam stealthily removed the belongings of the mother and the minor daughter and it amounts to theft. When the police wanted to investigate into the complaint, the said Rajarathinam filed a suit against the State, Police and the mother seeking for a relief of permanent injunction restraining the defendant from preferring vexatious complaint and for permanent injunction restraining the defendant therein from removing the articles from Rajarathinam. In this factual circumstances of the case, on a reading of the pleadings, the Court came to the conclusion that the suit filed against the State and the police officer and the wife is a vexatious one and on that peculiar facts and circumstances of the case, the Court, after satisfying itself that there was no chance for the said Rajarathinam to succeed in the suit, invoked its power under Article 227 of the Constitution of India and stopped the proceedings preferred by the said Rajarathinam summarily by ordering striking off the plaint.

12. S. Viswanathan v. Sri Muruga Agencies, 2002 (1) TLNJ 13 is a case in which it was held that the facts of that case disclosed a dismal and deliberate case of collusion between the sub tenant and the chief tenant in a rent control proceedings. On the facts of that case, this Court has come to the conclusion that the chief tenant and the sub tenant played hide and seek and hood wink process of law. In those circumstances, after making a cautionary note that the power under Article 227 of the Constitution of India could be exercised sparingly to strike off a plaint in a suit pending before a trial Court, except in exceptional circumstances, the Court brought that case under the purview of exceptional circumstances carved out.

13. K.K. Swaminathan v. Srinivasagam, 2004 1 LW 250 was a case filed seeking for cancellation of a decree passed in an earlier suit, which was confirmed on appeal and in second appeal on the ground that the said decree was obtained by use of a false document. In that suit, an application was filed seeking to send the suit promissory note to the handwriting expert and it was dismissed and a decree was passed after full trial. When the execution petition was pending, the dismissal of the application seeking to send the promissory note to the handwriting expert, has been carried on in a revision before this Court and in those factual circumstances of the case, having found that the validity and genuineness of the promissory note was directly and substantially in issue in the earlier suit which has been affirmed in the second appeal by the High Court, the subsequent suit was held to be an abuse of process of law and the Court passed an order for striking off the plaint.

14. Hunter v. Chief Constable of West Midlands, (1981) 3 All ER 727 is also a case in which a civil action has been brought claiming damages on the allegation against the police officer for assaulting the petitioner to procure confessional statement. That civil action was regarded as an abuse of process of law on the ground that the very same allegation that the petitioner was assaulted by the police officer to procure confessional statement has been raised before the criminal Court which was negatived and the petitioner was convicted in a criminal case. 15. I am of the view that none of the above said decisions would advance the case of the petitioner as there is an ocean of difference between the facts of those cases and the facts of the present case. The earlier suit filed by the respondents was a suit for injunction in respect of 180 kuzhies of Manaikattu in which, on the basis of the oral evidence, a decree for injunction has been granted in favour of the respondent only in respect of 100 kuzhies. A decree drawn in that suit is also made available. That also indicates that the injunction decree was granted only in respect of 100 kuzhies for the respondents herein. No other decree was granted. Some of the observations in the judgment has been read out to contend that a decree has been granted in favour of the vendor of the petitioner in respect of 60 kuzhies and in respect of the remaining 20 kuzhies it was found that it belonged to nobody. Whether that decree could be regarded as a decree granted in favour of the petitioner in respect of 60 kuzhies is a moot question to be decided. Certain observations made in the suit notice has also been highlighted before this court to contend that the respondents have no regard to the orders and judgments passed by the Courts. I am of the view that the reasoning stated in the notice cannot by itself be a factor to reject the plaint by invoking the supervisory jurisdiction. If the petitioner is of the view that he is having a good case to have the plaint rejected, he would very well place the materials before the trial Court itself and seek for the required relief in his favour by placing the materials on which reliance has been placed before this Court. Above all, the trial Court has not committed any manifest error except ordering issuance of summons to defendants in the suit filed by the respondents herein.

16. The supervisory jurisdiction of this Court could be invoked only when the trial Court has committed any error. Mere filing of a suit by the respondents and taking the suit on the file by the trial Court cannot be regarded as an act on the part of the trial Court to transgress its jurisdiction or its bound. Of course, the party who files the suit might have filed the suit suppressing material facts or made up the suit to his convenience for seeking the relief which is not otherwise entitled to. But that facto has to be considered by the trial court during the relevant point of time. There is no impediment or embargo for the petitioner to put forth his contentions before the trial court to strike off the plaint at the threshold. As this Court is relegating the petitioner to go before the trial Court for the relief, the Court has restrained itself from going into the facts of the case, as any observation made by this Court would have a bearing on the suit, which is pending before the trial court. Of course, the petitioner is also having an effective remedy in the Code of Civil Procedure itself to have the suit struck off and he could very well avail that remedy. On the above said reasoning, I am not inclined to grant the relief as prayed for in the revision.

17. Yet another factor is also to be taken into consideration. Of-late, High Courts are flooded with cases and the Courts have reached a saturation point with the backlog starring on the face and the disposal of the cases by the Courts for the past four or five years could never match the institution of the cases. When Courts are facing such a situation, this sort of approaching this Court can be avoided. By saying so, this Court should not be misunderstood of shirking of its responsibilities, but it has to be taken in the way it is stated, that is, the Court has just high lighted the state of affairs. This Court also sends a cautionary note to the litigant public to approach the court of first instance first.

18. For the reasons stated in the foregoing paragraphs, this Court is of the view that this is not a fit case for this Court to invoke the jurisdiction of this Court under Article 227 of the Constitution of India. The petitioner can avail the common law remedy available to him first. The revision is dismissed with the above observations. The trial Court, on the petitioner approaching it for the required relief, shall dispose of the same in accordance with law, without in any way being influenced by anything said in this order. The revision is dismissed. No costs.

VCJ/VCS

Ganapathy Subramanian Petitioner v. S. Ramalingam & 23 Others S

Structured Summary of the Opinion (Article 227 Revision)

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

Petitioner's Arguments

Respondents' Arguments

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

Ganapathy Subramanian Petitioner v. S. Ramalingam & 23 Others S

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