ARJUN SINGH vs MOHINDRA KUMAR & ORS.

The Supreme Court held that there is no material difference between 'good cause' under Order IX, Rule 3 and 'sufficient cause' under Order IX, Rule 13 of the Code of Civil Procedure, 1908. The Court clarified that the principle of res judicata applies not only to Section 11 but also to different stages of the same suit. It ruled that an interlocutory order under Order IX, Rule 7 does not bar the hearing of an application under Order IX, Rule 13, as it does not determine any issues in controversy. The appeal was allowed, setting aside the High Court's dismissal based on res judicata.