MALKHAN SINGH vs SOHAN SINGH & ORS.

The Supreme Court held that under Section 49 of the Uttar Pradesh Consolidation of Holdings Act, the decision of consolidation authorities does not operate as res judicata if there has been no adjudication of the rights and title of the claimant. The Court found that the High Court erred in dismissing the suit on the grounds of res judicata, as the issue of adoption had not been previously adjudicated. The appeal was allowed, reinstating the trial court's decision that Malkhan Singh was not the adopted son of Kishan Singh.