Lehna Singh (D) by LRs. vs. Gurnam Singh (D) by LRs. & Ors.
Background
This was a review petition filed by Lehna Singh's legal heirs against the Supreme Court's own 2019 judgment in Civil Appeal No. 6567 of 2014, a decades-old property/injunction dispute between two families. In that 2019 judgment, the Court had ruled that the Punjab and Haryana High Court exceeded its powers under Section 100 of the Civil Procedure Code by re-examining facts in second appeal without framing a "substantial question of law," and had restored the First Appellate Court's decree in favour of the review petitioner's opponents. The review was sought because a subsequent Constitution Bench decision (Pankajakshi) clarified that second appeals from Punjab and Haryana are governed by Section 41 of the Punjab Courts Act, 1918, not Section 100 CPC, meaning no substantial question of law needs to be framed there.
Decision Breakdown
The Supreme Court found that its 2019 judgment contained an "error apparent on the face of the record" in light of the later Constitution Bench ruling, took the unusual step of recalling its own earlier judgment, and restored the civil appeal for fresh hearing on merits. Re-examining the underlying evidence itself, the Court concluded that the First Appellate Court (District Judge) had wrongly reversed the trial court's findings, and that the High Court had, in fact, correctly set aside the First Appellate Court's decision to restore the trial court's decree. Accordingly, the review was allowed, the appeal was reheard, and, reversing the outcome of the Court's own 2019 decision, the civil appeal was dismissed.
Lesson Learnt
A Supreme Court judgment can be reviewed and even reversed by the Court itself if a later binding precedent shows the earlier decision applied the wrong legal standard, and litigants in Punjab and Haryana should know that second appeals there follow the state's own Punjab Courts Act procedure, not the general CPC framework used elsewhere.