Declaratory relief and libel claims fail where prior adjudication, claim-splitting, and privilege defeat the pleaded cause of action.

Declaratory relief was treated as barred because an earlier adjudication had already negatived territorial jurisdiction, the same declaration had been pursued in prior proceedings without leave, and the relief sought would in any event bind only inter partes under the Specific Relief Act. The libel claim was also found unsustainable because the impugned publications were fair and accurate reports of judicial findings and were protected by privilege, leaving no arguable cause of action. The plaint was therefore rejected as maintainable neither in its declaratory nor damages aspect, and the proceedings ended with costs.

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Issues: (i) Whether the declaration claims were barred and liable to be rejected for want of territorial jurisdiction and for failure to comply with the rule against splitting claims; (ii) Whether the libel claim disclosed a cause of action or was liable to be struck out as frivolous, vexatious, and an abuse of process.

Issue (i): Whether the declaration claims were barred and liable to be rejected for want of territorial jurisdiction and for failure to comply with the rule against splitting claims.

Analysis: The Court held that the earlier adjudication had already negatived jurisdiction in relation to the declaration-based relief, and the present suit could not be used to reopen that issue. It also held that the plaintiffs had already claimed identical declaratory relief in earlier proceedings and could not, without obtaining leave in those proceedings, pursue the same relief in a fresh suit. The Court further held that the declaratory relief was in any event futile because a declaration under the Specific Relief Act is binding only inter partes and would not bind Indian authorities in the manner sought by the plaintiffs.

Conclusion: The declaration claims were barred and were rejected against the plaintiffs.

Issue (ii): Whether the libel claim disclosed a cause of action or was liable to be struck out as frivolous, vexatious, and an abuse of process.

Analysis: The Court held that the impugned publications were fair and accurate reports of judicial findings and therefore enjoyed privilege. It further held that, even assuming publication, the claim could not succeed because the reports were protected and the plaintiffs had no arguable case. The Court also found that the libel allegations had been coupled with the declaratory relief to create an artificial cause of action and to continue vexatious litigation.

Conclusion: The libel claim disclosed no cause of action and was struck out as an abuse of process.

Final Conclusion: The suit was not maintainable in its declaratory aspect and the damages claim was also unsustainable, so the plaint was rejected and the proceedings ended against the plaintiffs with costs.

Ratio Decidendi: A plaint may be rejected where the substantive relief is barred by law or prior adjudication, or where the pleaded defamation claim is answerable by privilege and the suit as framed amounts to an abuse of process.

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