Highlighting a fundamental legal principle, the Supreme Court emphasized that once a higher court issues a final ruling, any previous decision by a lower court on the same matter merges with it. This principle ensures that only one binding and operative decree governs a case at any given time.
The doctrine of merger, as clarified by the Court, establishes that a superior court’s judgment takes precedence over a trial court’s decision, rendering the latter merged and subordinate. This concept has significant implications, particularly in cases where decrees are altered, confirmed, or set aside during appeals.
The case in question involved a dispute over the specific performance of a sale agreement. The trial court had directed the plaintiff to deposit the balance sale consideration within 20 days. However, the plaintiff’s failure to comply prompted appellate proceedings, eventually reaching the Punjab & Haryana High Court. The High Court allowed the second appeal but did not impose a new timeline for the deposit.
When the matter reached the Supreme Court, the question arose: could the trial court’s original 20-day deadline still hold after the High Court’s ruling?
Justice JB Pardiwala clarified the situation, stating that the High Court’s decree superseded the trial court’s directive. Under the doctrine of merger, the timeline set by the trial court ceased to be applicable once the High Court issued its ruling without specifying a deadline.
The Court further observed that specific performance, as an equitable remedy, allows flexibility. The plaintiff retains the option to request an extension for fulfilling their obligations, even after the High Court’s decree.
This judgment reaffirms the hierarchical nature of judicial decrees, ensuring clarity and uniformity in the enforcement of legal orders while emphasizing the equitable nature of remedies like specific performance.
