GANGABAI W/O RAMBILAS GILDA vs CHHABUBAI W/O PUKHARAJJI GANDHI

The Supreme Court held that findings regarding title to immovable property in Small Cause suits cannot operate as res judicata in subsequent civil suits where the title is directly in issue, as per Section 11 of the Code of Civil Procedure. The Court clarified that a matter must be directly and substantially decided in the former suit for res judicata to apply, and incidental issues do not suffice. The appeal was dismissed, affirming that the earlier Small Cause Court decrees did not bar the respondent's claim of ownership.