N.K. MOHAMMAD SULAIMAN vs N. C. MOHAMMAD ISMAIL AND OTHERS

The Supreme Court held that a decree obtained against some heirs of a deceased Muslim debtor is binding on the entire estate if those heirs were sufficiently represented in the suit. The Court clarified that the question of whether the decree binds the entire estate or only those impleaded is a matter of procedural law, not personal law. It was determined that if a creditor conducts a bona fide inquiry and believes they have identified all interested parties, the decree will be binding on the entire estate, as established in Daya Rain and others v. Shyam Sundari & others [1965] 1 S.C.R. 231.