Interim injunction does not revive automatically on restoration of a suit without express judicial direction.

An interim injunction does not automatically revive when a suit dismissed for default is restored. The text distinguishes ancillary orders, which support the main adjudication and may continue on restoration, from supplemental proceedings such as temporary injunctions and attachment before judgment, which affect substantive rights and third-party interests and therefore do not survive unless the court expressly directs revival. In the absence of a statutory mandate or specific judicial order, restoration of the suit does not reactivate such interlocutory relief. The stated result is that the injunction did not revive automatically and the impugned order was set aside.

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Issues: Whether an interim order of injunction automatically revives when a suit dismissed for default is restored.

Analysis: The distinction drawn was between ancillary or incidental orders, which aid the main adjudication and may revive with restoration, and supplemental proceedings, which are extraordinary and do not necessarily survive the dismissal of the suit. Temporary injunctions and orders of attachment before judgment were treated as supplemental in nature because they can affect substantive rights and third-party interests, and their continuation after restoration would prejudice parties without an express judicial order. The reasoning emphasised that, in the absence of a statutory mandate, restoration of the suit does not by itself reactivate such interlocutory relief.

Conclusion: The interim order of injunction did not revive automatically on restoration of the suit.

Final Conclusion: The appeal succeeded and the impugned order was set aside.

Ratio Decidendi: An interlocutory order that is supplemental in nature does not automatically revive upon restoration of a suit unless the court expressly directs its revival.

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