Does Dismissal of a Second Appeal for Non-Prosecution Establish or Affect Any Substantive Legal Principle or Precedent?

A second appeal was dismissed for non-prosecution after the appellants failed to appear before the High Court of Punjab & Haryana; the case reaffirms that procedural default leads to disposal without adjudication on merits and carries no substantive precedential value.

 

Summary

Category Data
Case Name RSA/2093/1993 of GURJANT SINGH Vs GURMAIL SINGH
CNR PHHC010263341993
Date of Registration 17-10-2008
Decision Date 31-10-2025
Disposal Nature DISMISSED
Judgment Author MR. JUSTICE PARMOD GOYAL
Court High Court of Punjab & Haryana
Precedent Value No substantive precedent value; disposed for non-prosecution
Type of Law Civil Appellate Procedure
Ratio Decidendi

The court dismissed the second appeal as none appeared on behalf of the appellants despite repeated calls. The decision was not on merits but was procedural, resting solely on the failure to prosecute the appeal. Pending applications, if any, were also disposed. No legal principle or substantive law was determined or clarified in the order.

Facts as Summarised by the Court

The appellants failed to appear before the court despite repeated calls. The court dismissed the appeal for non-prosecution and disposed of pending applications, if any.

Practical Impact

Category Impact
Binding On None, as no legal issue was adjudicated.
Persuasive For None, as the order was procedural, not substantive.

What’s New / What Lawyers Should Note

  • Reiterates that appeals can be dismissed for non-prosecution if the appellant fails to appear.
  • No legal issue was considered or decided; no new legal principle established.
  • The dismissal does not create precedent or affect substantive law.
  • Lawyers should ensure diligence in appearance or move for restoration if dismissed for non-prosecution.

Summary of Legal Reasoning

  • The court called the matter several times for appearance of the appellants.
  • In the absence of their counsel or any representation, the court exercised its discretion to dismiss the appeal for non-prosecution.
  • The court expressly limited its order to procedural grounds; there was no consideration of substantive legal rights or issues.

Arguments by the Parties

Petitioner (Appellants):

  • No arguments advanced; none appeared.

Respondent:

  • Represented by counsel.

Factual Background

The matter arose as a second appeal before the High Court of Punjab & Haryana, registered as RSA-2093-1993. On the date fixed, none appeared for the appellants despite repeated calls. The court dismissed the appeal for non-prosecution and disposed of any pending applications accordingly.

Statutory Analysis

  • No statutory provisions were interpreted or discussed in the text of the order.
  • The dismissal was based on procedural practice regarding non-appearance and non-prosecution in appellate proceedings.

Dissenting / Concurring Opinion Summary

None; single-judge order with no separate opinions.

Procedural Innovations

  • None reflected in the order; standard procedure for dismissal for non-prosecution was followed.
  • No new procedural precedent set.

Alert Indicators

  • Precedent Followed – Dismissal for non-prosecution follows established appellate procedure.

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