Settled disputes and withdrawn suits can extinguish interim relief, while interlocutory proceedings cannot be used to litigate title claims.

Where the principal dispute between contracting parties had been settled by later agreements and a consent award, and one suit had been withdrawn, interim orders based on that suit lapsed with it. The Court noted that the remaining suits, insofar as they sought relief against the settling party, no longer disclosed a live cause, and independent title claims could not be adjudicated through interlocutory proceedings in rival suits. It further treated the prolonged multiplicity of proceedings, repeated interim challenges, and attempts to secure substantive relief at an interim stage as an abuse of process and misuse of discretionary jurisdiction under Article 136. The special leave petitions were dismissed as infructuous, connected interim orders lapsed, and exemplary costs were imposed.

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Issues: Whether the special leave petitions arising from interlocutory orders in the pending suits survived after withdrawal of one suit and settlement between the principal parties, and whether the continuance of the remaining suits and connected proceedings constituted an abuse of the judicial process.

Analysis: The disputes between the principal contracting parties had been substantially settled by later agreements and a consent award, and the suit withdrawn by one party carried with it the interim orders passed in those proceedings. The remaining suits, so far as they sought relief against the settling party, no longer disclosed a live cause. As against the other parties, the claims depended on a title or right that had not yet been independently established, and such title could not be adjudicated in the interlocutory proceedings arising out of the suits filed by the rival claimants. The Court also found that the prolonged multiplicity of proceedings, repeated interlocutory challenges, and attempts to secure substantive adjudication at an interim stage amounted to abuse of the process of court and a misuse of the discretionary jurisdiction under Article 136.

Conclusion: The special leave petitions were not fit for interference and were dismissed as infructuous. The connected interim orders also lapsed, and exemplary costs were imposed on the concerned parties.

Final Conclusion: The litigation was brought to an end at the SLP stage, with the Court declining to adjudicate the underlying title disputes and leaving any surviving substantive claims to be worked out in the appropriate suit.

Ratio Decidendi: Where the principal dispute has been settled or the underlying suit withdrawn, interlocutory orders founded on that dispute lapse, and a party cannot use such proceedings to obtain adjudication of independent title claims or to perpetuate litigation that amounts to an abuse of process.

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