Fraud on the court permits annulment of final orders where material facts were deliberately suppressed to obtain relief.

Fraud vitiates judicial proceedings, and a court of record may nullify an order obtained by practising fraud even if earlier procedural orders or finality had attached. The Supreme Court reiterated that a party cannot rely on delay, review refusal, or other procedural obstacles to preserve an order shown to have been procured by falsehood. On the facts, the claimant suppressed material facts about title and possession while asserting entitlement under the Act, and that concealment went to the root of the claim. The Forest Tribunal's order was therefore obtained by fraud and was liable to be set aside, leaving the claimant disentitled to the relief sought.

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Issues: (i) Whether an order obtained by fraud on the court can be nullified despite earlier finality and procedural refusals to interfere. (ii) Whether the appellant had suppressed material facts and procured the Forest Tribunal's order by fraud so as to disentitle him to relief under the Act.

Issue (i): Whether an order obtained by fraud on the court can be nullified despite earlier finality and procedural refusals to interfere.

Analysis: Fraud vitiates judicial proceedings and a court of record has the power to set aside or nullify an order obtained by practising fraud. Finality attached to an earlier order, or refusal to interfere on procedural grounds such as delay or review, does not protect a judgment that is shown to have been procured by fraud. The proper course is to move the court that rendered the decision, and the court is not precluded from undoing its own fraudulent process.

Conclusion: The order could validly be set aside if it was shown to have been obtained by fraud, notwithstanding earlier procedural orders.

Issue (ii): Whether the appellant had suppressed material facts and procured the Forest Tribunal's order by fraud so as to disentitle him to relief under the Act.

Analysis: The appellant's entitlement under Section 3(3) of the Act depended on valid title, possession, and an intention to cultivate. The material on record showed that he had already parted with almost the entire extent originally purchased, yet he pursued the claim as if he continued to hold title and possession over the application schedule land. The concealment went to the root of the claim and was not a mere case of perjured evidence. The claim was founded on a false and knowingly suppressed factual basis, which amounted to fraud on the tribunal.

Conclusion: The appellant procured the Forest Tribunal's order by fraud and was not entitled to the relief claimed.

Final Conclusion: The High Court's action in setting aside the Tribunal's order was upheld, and the appellant's challenge failed.

Ratio Decidendi: An order obtained by deliberate suppression of material facts and false assertion of entitlement is vitiated by fraud, and such an order can be annulled by the court even after earlier finality has attached.

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