Finality of prior adjudication binds parties and limits executive power to cancel land grants or alter site rights.

A prior adjudication between the same parties remains binding in later proceedings, and executive authorities cannot reopen issues already finally decided or disregard findings on waiver, grant validity and entitlement. The text also explains that a grant of land for house sites is not void merely because land-reform restrictions apply to agricultural land, where the statutory scheme permits conversion and grants of building sites. Administrative directions cancelling the grant, restoring vacant sites, or compelling transfer of civic amenity and road land are described as unsustainable where they conflict with vested layout conditions and binding prior findings.

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Issues: (i) whether the prior High Court judgment had attained finality and bound the parties so as to preclude re-agitation of the validity of the 1979 grant and the effect of the 1980 agreement and withdrawal of the earlier suit; (ii) whether the 1979 grant of land for house sites was void on the ground that the Karnataka Land Reforms Act barred such grant; (iii) whether the Minister's order cancelling the grant, directing transfer of vacant sites, and directing handover of civic amenity sites and ring-road land could be sustained.

Issue (i): whether the prior High Court judgment had attained finality and bound the parties so as to preclude re-agitation of the validity of the 1979 grant and the effect of the 1980 agreement and withdrawal of the earlier suit.

Analysis: The earlier Division Bench judgment had expressly decided that the State had power to sanction the grant notwithstanding pendency of the occupancy claim, that the inamdars would be entitled only to the price if their occupancy claim succeeded, and that by the 1980 agreement, withdrawal of the suit, and receipt of consideration, the inamdars had waived their right to occupy the land. The later order of this Court refusing special leave did not attract merger and did not displace those findings, but the earlier findings nevertheless remained binding inter partes. The High Court's view that the earlier decision was per incuriam could not defeat res judicata.

Conclusion: The prior adjudication was final and binding, and the issue could not be reopened.

Issue (ii): whether the 1979 grant of land for house sites was void on the ground that the Karnataka Land Reforms Act barred such grant.

Analysis: The restrictions in the land-reforms provisions applied to agricultural land, while the land grant was made subject to conversion and the land-revenue regime permitted diversion of agricultural land for non-agricultural use on payment of fine. The grant rules also contemplated grants of building sites. Read harmoniously, the statutory scheme did not invalidate the grant merely because it was for house sites. The agreement entered into by the inamdars, and the acceptance of money under it, further supported the conclusion that they had waived any inconsistent claim.

Conclusion: The grant was not void ab initio on this ground.

Issue (iii): whether the Minister's order cancelling the grant, directing transfer of vacant sites, and directing handover of civic amenity sites and ring-road land could be sustained.

Analysis: Since the earlier binding decision had upheld the grant and the inamdars' entitlement was confined to the price of the land, the Minister could not ignore those findings and cancel the grant or direct restoration of vacant sites. The civic amenity sites and the road portions had vested with the development authority under the sanctioned layout conditions, so the State could not direct their free handover to the inamdars or treat the ring-road land as private property for compensation purposes.

Conclusion: The Minister's directions were unsustainable and were set aside.

Final Conclusion: The common High Court judgment was set aside, the writ petitions succeeded, and the challenged administrative directions were annulled; the connected later appeal was remanded for fresh consideration in conformity with this decision.

Ratio Decidendi: A prior adjudication that has attained finality between the same parties binds them in later proceedings, and an executive authority cannot ignore such binding findings to cancel a grant or alter rights flowing from it; statutory restrictions on agricultural land do not invalidate a site grant where the legal scheme permits conversion and site allotment.

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