State Of West Bengal vs PAM Developments Private Limited 2025 INSC 69 - Ss 12, 80 CPC

Code of Civil Procedure 1908 - Section 12 & Order XXIII Rule 1 - No suit lies on the same cause of action if the plaintiff has abandoned their claim - This principle is not attracted when the circumstances give rise to a continuous cause of action resulting in a situation where both the amendment applications were filed at different points of time and the former was not adjudicated on merits. - A cause of action is continuing when the act alleged to be wrongful is repeating over a period of time, and consequently extending the limitation period. Cause of action is a bundle of facts giving rise to a legal right. (Para 21-24)

Code of Civil Procedure 1908 - Section 80 - When amendment sought amounts to a continuous cause of action and maintains the nature and character of the suit and to that extent, Section 80 of the CPC is irrelevant. (Para 26)