Case Law Analysis
|Supreme Court of India
CPC Order XX Rule 4 | Ex Parte Decrees Must Frame Issues Even Without Defendant: SC Mandates Procedural Fairness
The Supreme Court ruled that ex parte judgments under CPC Order XX Rule 4 must explicitly state points for determination, failing which the decree is vitiated. The trial court’s dismissal of a specific performance suit on unpleaded title grounds-without framing issues-was held procedurally flawed, reinforcing judicial discipline even in uncontested proceedings.