S.G. Barapatre & Ors. v. Shri Ananta Gajanan Gaiki & Ors.
Background
The appellants, employees who had earlier claimed Scheduled Tribe status, were directed by the Bombay High Court (Nagpur Bench) to be discontinued from service and to have their past payments recovered after they declined to subject themselves to caste scrutiny. However, the very same underlying issue concerning these appellants had already been decided by a Division Bench of the same High Court in an earlier 2012 judgment, which had become final after the employer's special leave petition and review petition against it were both dismissed by the Supreme Court.
Decision Breakdown
The Supreme Court held that since the 2012 judgment had attained finality as between these parties, the limited protections and benefits specifically granted to the appellants under paragraph 18 of that earlier judgment could not be undone or taken away through the later, collateral High Court proceedings under appeal. The Court clarified that the appellants would only be entitled to the benefits specifically spelt out in that paragraph 18: essentially being placed in the general category as on 28.11.2000, ranked below the last general-category candidate of that date. The impugned High Court orders were modified to this extent, and the appeals were accordingly disposed of with no order as to costs.
Lesson Learnt
Once a judgment between the same parties on the same issue becomes final (including after an unsuccessful appeal and review), its findings cannot be reopened or overridden through a separate, later round of litigation on a related but distinct cause of action: a basic application of the principle that a final judgment binds the parties on the matters it actually decided.