T. Gnanavel vs T.S.Kanagaraj And Anr

The Supreme Court interpreted Order XXII Rule 4 of the Code of Civil Procedure, holding that an ex parte decree becomes a nullity if the sole defendant dies and the plaintiff fails to bring the heirs on record, even if an exemption is granted. The Court emphasized that the death of the defendant must be acknowledged in the proceedings to avoid abatement. The appeal was dismissed, affirming the High Court's decision that the decree was void due to non-compliance with procedural requirements regarding the defendant's death.