Sri Gangai Vinayagar Temple v. Meenakshi Ammal
Background
Tenants who operated a cinema challenged a temple trust's transfer of the leased property. Their suit and two rent-recovery suits were tried together and decided through one judgment but three separate decrees. The tenants appealed only the decree in one rent suit, leaving adverse determinations in the connected cases unchallenged.
Decision Breakdown
The Supreme Court allowed the trust's appeal and held that the tenants could not reopen the title dispute through their selected appeal. They had deliberately placed ownership and the trustees' power to sell directly in issue in all three suits. The unappealed decrees therefore became final and barred renewed adjudication of that common dispute. The Court distinguished suits formally consolidated into one proceeding from separately decreed suits merely heard through common evidence and a common judgment; it did not require an appeal against every unfavourable observation.
Lesson Learnt
If connected suits produce separate adverse decrees on the same dispute, review the need to appeal each decree. Challenging only one may leave another final decision that prevents the issue from being reopened.