Case of Sultan Said Ibrahim vs Pakistan, SC Judgement Dated 23rd May 2025. The apex court held that where a party is substituted as a legal representative under Order XXII Rule 4 CPC and does not object at that stage, the order attains finality; a later application under Order I Rule 10 CPC to delete that party is barred by the doctrine of res judicata. The ruling also re-affirms that (i) tenancy pleas cannot be raised belatedly to defeat a confirmed specific-performance decree, and (ii) delivery of possession is implicit when the vendor held exclusive possession at the time of the decree.
