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Maha P. & Ors. vs. The State of Kerala & Ors.

Civil Appeal · 2022 INSC 1311Decided 22 Jul 2022
Civil Appeal No. 3654 of 2022

Background

In an earlier judgment dated 18 May 2022, this Court had recorded a statement (drawn from a Single Judge's order) that the Kerala Government had extended the deadline for NRI candidates to cure defects in attestation of documents up to 31 March 2022. The State of Kerala filed this application saying that, as a matter of fact, there was no such extension and the real last date was 2 March 2022, and that the incidental observation in the Supreme Court's judgment had triggered fresh litigation in the High Court.

Decision Breakdown

The Court held that whether there was any extension of time beyond 2 March 2022 was never actually an issue it had been asked to decide in the earlier proceedings: the reference to 31 March 2022 was simply a recital of what appeared in the lower court's order, not a finding of this Court. It therefore clarified that the disputed factual question of the correct cut-off date should be decided in whatever appropriate proceedings raise it, on the basis of the actual record, and disposed of the modification application with that clarification.

Lesson Learnt

A passing factual recital in a Supreme Court judgment (describing what a lower court's order said) is not itself a binding finding by the Supreme Court on that fact, and a party affected by such a recital can apply for clarification instead of treating it as res judicata.

Official source (sci.gov.in)View Judgment (PDF)

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