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Are Appeals Against Order XXIII Rule 3 Maintainable?

Kavya Tekriwal & Karan Scaria, Jindal Global Law School

A critical analysis of Pushpa Devi Bhagat v Rajinder Singh and Ors. (2006) 5 SCC 566


The word ‘compromise’ means settling a dispute with the mutual consent of parties. When such compromise is made, a litigation battle is put an end to. For suits filed in courts, it is up to the discretion of the parties to the suit, to compromise by agreement. In fact, the case of Hiralal Moolchand v. Barot Raman Lal1, laid down a general principle which stated that if a dispute can be resolved by suits, they can also be resolved with the help of a compromise. Therefore, a provision in the Civil Procedure Code (hereinafter referred to as ‘the Code’) has been given for the withdrawal or compromise of a suit.

Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878


Accessibility: Open Access

License: Creative Commons 4.0

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​All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.


The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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