Pankajbhai Rameshbhai Zalavadiya vs Jethabhai Kalabhai Zalavadiya ...

The Supreme Court held that the dismissal of an application under Order 22 Rule 4 of the Code of Civil Procedure does not bar a subsequent application under Order 1 Rule 10, as the two provisions serve different purposes. The Court affirmed the trial Court's decision that a suit against a deceased person is a nullity, and thus the legal representatives cannot be joined under Order 22 Rule 4. The appeal was dismissed, upholding the High Court's ruling that the application for impleading the heirs was rightly rejected.