Does Dismissal of a Revision Petition for One Co-Interested Party Mandate Dismissal of Another’s Petition on Same Grounds? — Reaffirmation of Consistent Precedent

The Punjab and Haryana High Court has upheld the principle that where co-interested parties have an identity of interest and one party’s revision petition against an order stands dismissed, the same outcome must follow for another similarly situated party. This judgment reaffirms existing precedent and serves as binding authority within the court’s jurisdiction for similarly situated revision petitions across civil matters.

 

Summary

Category Data
Case Name CR/5893/2025 of BALPREET SINGH Vs JASPAL KAUR AND OTHERS
CNR PHHC011372062025
Date of Registration 26-08-2025
Decision Date 01-09-2025
Disposal Nature DISMISSED
Judgment Author MR. JUSTICE DEEPAK GUPTA
Court High Court of Punjab and Haryana
Precedent Value Binding within jurisdiction
Overrules / Affirms Affirms prior dismissal in CR No.5737 of 2025
Type of Law Civil Procedure
Questions of Law Whether, when interests of revision petitioners are identical, dismissal of one party’s revision petition mandates dismissal of the other.
Ratio Decidendi

When parties have identical interests in assailing the same impugned order and the earlier revision petition of one such party stands dismissed, another party with the same interest cannot maintain a separate revision petition.

This promotes judicial consistency and prevents multiplicity of proceedings. The present revision petition was accordingly dismissed in view of the prior order.

Judgments Relied Upon CR No.5737 of 2025 (Punjab and Haryana High Court, 25.08.2025)
Logic / Jurisprudence / Authorities Relied Upon by the Court Dismissal based on identical interests and prior decision on identical facts.
Facts as Summarised by the Court The petitioner’s brother, Johnpreet Singh, had already assailed the impugned order dated 07.08.2025 by filing CR No.5737 of 2025, which was dismissed by this court vide order dated 25.08.2025. The interests of the petitioner and his brother were stated to be the same.
Citations Order dated 25.08.2025 in CR No.5737 of 2025; current order dated 01.09.2025

Practical Impact

Category Impact
Binding On All subordinate courts within the jurisdiction of the High Court of Punjab and Haryana
Persuasive For Other High Courts deciding identical or similar factual scenarios
Follows Dismissal order dated 25.08.2025 in CR No.5737 of 2025

What’s New / What Lawyers Should Note

  • The judgment underlines the non-maintainability of a subsequent revision petition by a co-interested party after the dismissal of an earlier one on identical grounds.
  • Any revision application filed by a party with interests identical to another who already faced dismissal for the same order will likewise stand dismissed.
  • Counsel should ascertain if a co-interested party’s petition has already been decided before filing or pursuing parallel proceedings.

Summary of Legal Reasoning

  • The court noted a statement from the petitioner’s counsel that the petitioner’s brother, Johnpreet Singh, previously challenged the same impugned order by way of CR No.5737 of 2025.
  • Both the petitioner and his brother were deemed to have identical interests concerning the impugned order.
  • Referring to its own order dated 25.08.2025 dismissing the earlier revision, the court held that the present revision was not maintainable and must also be dismissed.
  • The decision upholds the principle that parties, whose interests are congruent, cannot litigate the same cause after it has been adjudicated for one member of that group.

Arguments by the Parties

Petitioner

  • Asserted that the petitioner and his brother shared identical interests regarding the impugned order.
  • Brought to the court’s notice the fact of prior adjudication in CR No.5737 of 2025.

Respondent

  • Power of attorney filed on behalf of respondent No.1-caveator; specific arguments not detailed.

Factual Background

The petitioner filed a revision petition assailing an impugned order dated 07.08.2025. The petitioner’s brother, Johnpreet Singh, having the same interest, had previously challenged this order by filing CR No.5737 of 2025. The earlier revision petition was dismissed on 25.08.2025, and the present matter involved the question of whether a similarly interested co-party’s revision can be entertained after such a dismissal.

Statutory Analysis

  • The court applied principles of civil procedure regarding maintainability of revision petitions where interests of parties are identical and litigation would result in duplication.
  • No statutory provision was expressly interpreted beyond inherent powers to decide the maintainability of revision on such facts.

Alert Indicators

  • ✔ Precedent Followed – The judgment affirms consistent existing law and prior decision of the same court (CR No.5737 of 2025).

Citations

  • Order dated 25.08.2025 in CR No.5737 of 2025, Punjab and Haryana High Court
  • CR No.5893 of 2025, Punjab and Haryana High Court, order dated 01.09.2025

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