GRAM PANCHAYAT OF VILLAGE NAULAKHA vs UJAGAR SINGH .

The Supreme Court held that the Full Bench decision in Gram Panchayat, Village Bathoi Kalan, Patiala v. Jagar Ram, AIR (1991) P&H 159, which required a Panchayat to file an independent suit to challenge a collusive decree, is incorrect and contrary to Section 44 of the Indian Evidence Act. The Court established that a party can demonstrate that a judgment was obtained by collusion without needing a separate suit. The appeal by the Gram Panchayat was allowed, overturning the High Court's decision that had upheld the earlier decree as binding.