Res judicata applies to Land Tribunal proceedings, barring re-litigation of the same issue decided by a competent authority.

The principle of res judicata, including Explanation IV to Section 11 of the Code of Civil Procedure, 1908, can apply to Land Tribunal proceedings under the Kerala Land Reforms Act where a competent authority has already decided the same issue between the same parties after hearing them. The rule is based on public policy and finality of litigation, and it is not confined to civil courts. A prior adjudication on the same material circumstances therefore bars re-agitation of the controversy before the Tribunal. On the facts stated, the later application was barred by the earlier order.

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Issues: Whether the principle of res judicata, including the rule embodied in Explanation IV to Section 11 of the Code of Civil Procedure, 1908, applies to proceedings before the Land Tribunal under the Kerala Land Reforms Act.

Analysis: The rule of res judicata is founded on public policy and finality of litigation. It is not confined to civil courts alone and may apply to decisions of tribunals and other quasi-judicial bodies competent to decide rights after hearing the parties. A prior adjudication on the same issue between the same parties, made by a competent authority, can bar re-agitation of that issue in later proceedings before the Land Tribunal. On the facts, the earlier application had been decided against the petitioner on the same material circumstances, so the later application could not be maintained by re-opening the same controversy.

Conclusion: The principle of res judicata applied to the proceedings before the Land Tribunal, and the present application was barred by the prior order.

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