Corrupt practice pleadings must disclose complete material facts; vague election allegations may be struck out and recalled under inherent powers.

An election petition alleging corrupt practice must plead all material facts and the complete cause of action, including the essential particulars of time, place, persons, acts, and consent where relevant; vague or omnibus averments are insufficient and the deficient paragraphs were liable to be struck out. An earlier interlocutory order refusing partial strike-out did not attain finality on an erroneous jurisdictional view, because such an order could be recalled under inherent powers to prevent abuse of process and align the pleadings with the governing law.

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Issues: (i) Whether the earlier interlocutory order partly rejecting the strike-out application operated as res judicata and could not be recalled under the court's inherent powers. (ii) Whether the impugned paragraphs of the election petition disclosed the material facts and complete cause of action necessary to sustain allegations of corrupt practice under the Representation of the People Act, 1951.

Issue (i): Whether the earlier interlocutory order partly rejecting the strike-out application operated as res judicata and could not be recalled under the court's inherent powers.

Analysis: A decision on jurisdiction or on the existence of cause of action does not attain finality merely because it was previously decided; an erroneous view on jurisdiction cannot bar reconsideration as res judicata. The binding nature of law declared by the Supreme Court requires subordinate courts to conform their orders to that law, and inherent powers may be exercised to prevent abuse of process and to correct an order that permits a trial to continue where the petition itself does not disclose a valid cause of action.

Conclusion: The prior order was not barred by res judicata from being recalled under Section 151 of the Code of Civil Procedure, 1908.

Issue (ii): Whether the impugned paragraphs of the election petition disclosed the material facts and complete cause of action necessary to sustain allegations of corrupt practice under the Representation of the People Act, 1951.

Analysis: In an election petition alleging corrupt practice, Section 83 requires a concise statement of material facts and the fullest particulars. The pleadings must specify the essential ingredients of the charge, including the relevant time, place, persons involved, words used, nature of the alleged act, and the candidate's express or implied consent where required. Omnibus or vague pleadings, or attempts to supply essential facts later, do not cure the absence of foundational material facts. Where those essentials are missing, the petition discloses no cause of action and is liable to be struck out and rejected.

Conclusion: The impugned paragraphs did not disclose the required material facts or cause of action, and the election petition was liable to be dismissed.

Final Conclusion: The strike-out application succeeded, the deficient pleadings were removed, and the election petition could not survive for trial.

Ratio Decidendi: An election petition alleging corrupt practice must plead all material facts constituting the complete cause of action, and omission of essential particulars such as time, place, persons, acts, and consent renders the petition liable to rejection; an erroneous jurisdictional order may be recalled under inherent powers to prevent abuse of process.

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