Uppaluri Eswaramma v. State of Andhra Pradesh 2025 INSC 1488 - Doctrine Of Merger - Fraud Vitiates Everything
Law of Precedents - There is no merger of the judgment of the High Court, if the SLP has been rejected without any observation on merits, in which event, the parties before the High Court could exercise their right to seek review. (Para 9)
Fraud - ‘fraud vitiates everything’; even a judgment obtained from a competent court based on such fraud perpetrated. (Para 13)
Case Info
Key Details
- Case name: Smt. Uppaluri Eswaramma Etc. v. The State of Andhra Pradesh & Ors.
- Neutral citation: 2025 INSC 1488.
- Coram: Ahsanuddin Amanullah, J.; K. Vinod Chandran, J.
- Judgment date: November 28, 2025 (New Delhi).
Caselaws and Citations
- Kunhayammed v. State of Kerala, (2000) 6 SCC 359 — cited for the doctrine of non‑merger when SLP is dismissed without reasons and the maintainability of review despite SLP rejection.
Statutes/Laws Referred
- Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013.
- Revenue record references and administrative instruments: D‑Form Patta, Darkhast Register (DR), Adangal Register, Computerized Adangal, 10(1) Register.
- Principle: “Fraud vitiates everything” — applied to underscore that judgments procured by fraud cannot stand.