SHIVASHANKAR PRASAD SHAH & ORS. vs BAIKUNTH NATH SINGH & ORS.

The Supreme Court held that objections to execution proceedings are not barred by res judicata if the previous dismissal was due to the default of the decree-holder. It clarified that a plea must be heard and determined by the court to be considered res judicata under Section 11 of the Civil Procedure Code. The Court also ruled that execution proceedings are included under Section 4(d) of the Bihar Land Reforms Act, 1950, and thus could not proceed, affirming that the appellants' only remedy was to seek compensation under the Act.