BALDEVDAS SHIVLAL & ANR. vs FILMISTAN DISTRIBUTORS (INDIA) (P) LTD. & ORS.

The Supreme Court held that the High Court lacked jurisdiction under Section 115 of the Code of Civil Procedure to determine the issue of res judicata regarding a consent decree in a revision application. The Court clarified that the Trial Court's refusal to try certain preliminary issues did not constitute a 'case decided' as per Section 115. Consequently, the High Court's findings on the issue of res judicata were set aside, and the matter was remanded for further proceedings, allowing parties to present evidence.