AMRITSAGAR GUPTA & ORS. vs SUDESH BEHARI LAL & ORS.

The Supreme Court held that a decree against a manager of a Joint Hindu family can operate as res judicata against coparceners who were not parties to the earlier suit, as long as the manager was representing the family. The Court clarified that it is not necessary for the plaint to explicitly state that the manager was being sued as such; the circumstances must indicate that he was acting in that capacity. The appeal was allowed, affirming the trial court's decision that the suit was barred by res judicata based on the earlier decree.