Applicability of Res Judicata to Quasi-Judicial Authorities in India

The doctrine of res judicata, a well-established principle in civil law, posits that once a matter is finally decided by a competent court, the same issue cannot be re-agitated between the same parties. While this principle is traditionally applied to judicial proceedings, its applicability to quasi-judicial bodies has often been a matter of debate.

The recent Supreme Court judgment in M/S Faime Makers Pvt. Ltd. v. District Deputy Registrar, Co-operative Societies & Ors. (2025 INSC 423) has definitively reinforced the principle that quasi-judicial bodies are equally bound by res judicata. This article analyzes the factual matrix, legal findings, and broader implications of this important ruling.

Understanding Quasi-Judicial Bodies

Quasi-judicial bodies are administrative agencies that perform functions akin to courts. Though not courts in the strict sense, these bodies are vested with the authority to adjudicate disputes, conduct hearings, and issue binding decisions. Their powers usually emanate from statutes, and they are expected to function within the framework of natural justice. Common examples include consumer forums, tax tribunals, and authorities under rent control or cooperative housing laws.

Legal Journey of Faime Makers Pvt. Ltd.: A Case on Res Judicata

Background Facts

The dispute pertained to a piece of land in Jogeshwari (West), Mumbai, owned originally by Byramjee Jeejeebhoy Private Limited (BJPL) and later transferred to the appellant, M/s Faime Makers Pvt. Ltd., in 2010. Earlier, a lease deed had been executed in 1952 in favour of respondent No.3, who in turn granted development rights to a builder (respondent No.4). The builder constructed an unauthorized building comprising around 27 flats, which were later purchased by individuals forming Prakash Apartment Co-operative Housing Society (respondent No.2).

In 2020, respondent No.2 filed an application (No. 53 of 2020) before the District Deputy Registrar (Competent Authority) under Section 11 of the Maharashtra Ownership of Flats Act, 1963, seeking a unilateral assignment of leasehold rights. This application was rejected on 22.02.2021, citing unresolved legal complexities and directing the society to first obtain relief from a competent civil court.

Surprisingly, instead of following this direction, the society filed a second application (No. 101 of 2021) merely a month later. This time, the authority allowed the relief on 05.10.2021. The appellant’s challenge to this order failed before the Bombay High Court, but succeeded in appeal before the Supreme Court.

Key Legal Issues

• Whether a quasi-judicial body like the District Deputy Registrar is bound by the principles of res judicata?
• Whether the second application filed by the society was maintainable in light of the earlier unchallenged rejection?
• Whether the authority could grant relief without resolution of legal complexities as directed earlier?

Supreme Court’s Reasoning

Rejection of High Court’s View

The High Court had opined that the original rejection dated 22.02.2021 was vague and granted "unconditional liberty" to file a fresh application. The Supreme Court, however, held that this interpretation was erroneous. The earlier order explicitly stated that the complications surrounding title and transfer must be resolved in civil court before any relief can be granted.

"The order dated 22.02.2021 is very clear that complications had arisen because of various transactions inter se parties...the competent authority could not grant leasehold rights under the existing set of facts until and unless the complications were sorted out."

Res Judicata Binds Quasi-Judicial Bodies

The Court categorically ruled that the principle of res judicata applies to quasi-judicial authorities. It referred to two key precedents:

• Ujjam Bai v. State of Uttar Pradesh (1962 SCC OnLine SC 8): Where the Court held that findings of quasi-judicial tribunals bind unless reversed through proper legal channels.
• Abdul Kuddus v. Union of India [(2019) 6 SCC 604]: Reiterated that findings of a Foreigners Tribunal, being quasi-judicial, have a binding effect and cannot be disregarded.

These cases established that:

“Whenever a judicial or quasi-judicial tribunal gives a finding on law or fact, its findings cannot be impeached collaterally or in a second round and are binding until reversed in appeal or revision or by way of writ proceedings.”

Thus, the second application filed by the society was barred by res judicata, having been filed contrary to the final and unchallenged first rejection.

Review Powers Absent in Quasi-Judicial Setup

Another facet of the case involved the issue of review. The second application and its acceptance effectively amounted to a review of the earlier order, even though the authority had no statutory power of review under the 1963 Act.

"The Competent Authority is a statutory authority... until and unless specifically provided by Statute, it would not have power of review."

Finality of First Order

The appellant successfully argued that since the first order had attained finality and was never challenged, the subsequent proceedings lacked jurisdiction. The Supreme Court agreed and held:

"Once the said order has been accepted by the parties and has attained finality, the Competent Authority would not have jurisdiction to entertain a second application contrary to the findings and directions given..."

Significance of the Judgment

I) Reinforces Accountability of Quasi-Judicial Bodies

The decision underscores that quasi-judicial bodies cannot casually reverse or disregard their earlier final orders. It is a warning against administrative overreach and affirms procedural discipline.

II) Prevents Forum Shopping and Abuse of Process

By holding that the society was barred from refiling the same claim without complying with the earlier order, the Court curtailed the misuse of statutory remedies through multiple applications, preserving judicial efficiency.

III) Ensures Adherence to the Rule of Law

The ruling strengthens the notion that all authorities acting in a judicial or quasi-judicial capacity must respect binding precedents and established legal doctrines like res judicata.

IV) Clarifies Power to Review

The judgment clarifies that unless a statute expressly confers power to review, quasi-judicial bodies cannot reconsider their previous decisions, thereby preventing backdoor revisions and protecting legal certainty.

Comparative Analysis: Quasi-Judicial vs Judicial Finality

While courts have the inherent power to review under certain circumstances (e.g., review under CPC), quasi-judicial bodies are creations of statutes and must act within the powers conferred. This case serves as a textbook example of how statutory limitations bind such bodies. It also shows that the doctrine of res judicata, though rooted in civil court jurisprudence, transcends those boundaries when the functions performed involve adjudication.

Click Here to Read the Official Judgment 

Conclusion

The Supreme Court’s decision in M/S Faime Makers Pvt. Ltd. is a landmark judgment for regulatory and administrative law in India. It unequivocally holds that quasi-judicial authorities are bound by the principles of res judicata and cannot re-adjudicate matters already settled without statutory authorization. This judgment reinforces the need for consistency, finality, and procedural integrity in adjudication, irrespective of the forum. It acts as a crucial reminder for all statutory bodies exercising adjudicatory powers to respect the sanctity of prior decisions and avoid entertaining repeated or duplicative claims.