Substituted service requires strict statutory compliance; a mechanical order cannot sustain an ex parte decree.

Substituted service under Order V Rule 20 CPC is valid only if the court records satisfaction that the defendant is avoiding service or cannot be served in the ordinary way, and the mandatory steps under Order V Rule 17 are complied with. Here, the serving officer's report did not show the required affixation of summons, and the order permitting substituted service was cryptic and unsupported by the statutory preconditions. The ex parte decree was therefore procedurally infirm, and the High Court was right to set it aside; the challenge to that decision failed.

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Issues: (i) Whether the ex parte decree could be set aside for -compliance with the mandatory requirements governing service of summons and substituted service.

Analysis: The record showed that the serving officer could not find the defendant at the address mentioned in the summons, but the report did not show affixation of summons as required by Order V Rule 17. The order allowing substituted service under Order V Rule 20 was cryptic and did not reflect the court's satisfaction that the defendant was keeping out of the way or that service could not be effected in the ordinary manner. Substituted service is an exceptional mode and can be ordered only after strict compliance with the statutory safeguards. The High Court was therefore right in holding that the ex parte decree suffered from a procedural infirmity. The principles governing appeals against ex parte decrees and the available remedies were also noticed, but they did not assist the appellant.

Conclusion: The challenge to the setting aside of the ex parte decree failed, and the decree of the High Court was upheld.

Ratio Decidendi: Substituted service under Order V Rule 20 of the Code of Civil Procedure, 1908 is valid only when the court records due satisfaction on the statutory preconditions and the mandatory steps under Order V Rule 17 are complied with; a mechanical order for substituted service cannot sustain an ex parte decree.

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