INDER SINGH & ANR. vs THE FINANCIAL COMMISSIONER, PUNJAB & ORS.

The Supreme Court held that the doctrine of res judicata, as outlined in Section 11 of the Civil Procedure Code, does not apply to summary proceedings under the Pepsu Tenancy Agricultural Lands Act, 1955. The Court found that the earlier proceedings did not constitute a trial akin to a civil suit, thus allowing the appellants' second application under Section 22 to be maintainable. The High Court's ruling was set aside, affirming the appellants' rights to claim ownership based on their tenancy.