This article by Lavanya Verma describes what it means when a judgment reads as ‘case disposed’.

Case Status is Disposed. What does this mean?

• Case status is -“Disposed/ Disposal/ Disposition” are words used synonymously in the legal terminology when the case proceedings are completed. The measuring of the age of case ends on the day cases are “disposed” by the learned court.
• A civil or a criminal case is called disposed only after disposition of all the entered issues or charges in the case on the actual date of dismissal on the last issue/charge disposition.
• A criminal case in district court is said to be disposed on the date the case is bound over to superior court by way of a  superseding indictment, a waiver or finding of probable cause, or when the case is finally disposed in the district court by guilty plea, or dismissal or finding of no probable cause.

The disposition date is not when the data are entered into the automated system but the actual date of dismissal or order.

Nature of Case Disposal

• Contested – Otherwise

When the case has been opposed due to issues other than those relating to facts and findings like jurisdiction, then the matter was looked into and said to be disposed accordingly.

• Contested – Judgment

The pleadings in the case were disputed, so it was heard by the court, and the judgment was passed by the judge based on the merits deciding the case.

• Uncontested – Otherwise

When no one has opposed the facts and findings of the case it means uncontested. Thus, whatever has been filed has been accepted since no one opposed it and the case is disposed after hearing and now no more hearings are due further.

• Contested – Dismissed

The claim of the petitioner/plaintiff is disputed, as the petitioner/plaintiff may not have submitted required valid evidences. Dismissal on default is when the case is dismissed for not providing the evidence of the petitioner by remaining absent repeatedly, when process is fixed.

• Contested – Compromise

Suit was compromised after a keen contest and since nothing was left to decide with issues settled the matter was disposed.

• Dismissed

At many instances, the cases are dismissed even before a plea or trial by the prosecutor or the court. Also, cases are dismissed after the defendant has gone to trial, lost or won the appeal.

Dismissal of criminal cases: Section 203 CrPc

The first task for a defense attorney in a criminal case is to determine whether there are any grounds on which the case could be dismissed before a plea or trial. Common grounds for dismissal include:

• An improper criminal complaint or charging document
• Lack of probable cause to arrest
• An illegal stop or search
• Loss of evidence necessary to prove the defendant committed the crime.
• Lack of evidence to prove the defendant committed the crime
• An unavailable witness, necessary to prove the defendant committed the crime

Dismissal of Civil Cases

• Res Judicata (Section 10 & 11 Civil Procedure Court)

“Res Judicata” refers to an issue that has been already decided by the court in a previous case and hence, it cannot be heard again in a subsequent case.  The principle of Res Judicata is found on the increasing need for rendering finality to the judicial decisions. The court may dismiss the whole case out rightly, before the final hearing.

In the case of Satyadhyan Ghosal v. Smt. Deorajin Debi, where the principle of Res Judicata is invoked in the case of the different stages of proceedings in the same suit, some factors like the nature of the proceedings, the scope of the enquiry which the law provides for reaching a decision and also the specific provision made on matters related to such decisions are to be considered before the principle is held to be applicable.

Limitation

Some suits have to be filed within a specified time limit after which the court may dismiss it at once without considering any merits or details of the case.

Lack of Jurisdiction

A court may outrightly dismiss the case, if, it does not have requisite jurisdiction, be it pecuniary or territorial.

• Dismiss in default (Order  IX CPC)

1. If neither party appears on the date of hearing then the court is entitled to dismiss the suit, or
2. If the Defendant appears and the plaintiff does not appear, then the court is bound to dismiss the suit

An application under Rule 9 of Order IX for setting aside the dismissal for default of a suit was itself dismissed for default, in Doma Choudhary And Ors. vs Ram Naresh Lal And Ors.

Disposed as dismissed in limine

• If the appeal is dismissed in limine, then no fresh appeal can be filed on the same cause of action as it means that even prima facie, the appeal is devoid of any merit to warrant its admission.
• There is no dispute to the settled proposition of law that dismissal of the Special Leave Petition in limine simply means that this Court did not consider the case worth examining for the reason, which may be other than merit of the case. Nor such an order of this Court operates as res judicata.
• An order rejecting the SLP at the threshold without detailed reasons, therefore, does not constitute any declaration of law or a binding precedent.

Disposed is a much wider term than dismissed

When an action is dismissed then the court is closing the matter without taking a decision on the merits, and commonly for a procedural reason. Whereas, a disposition means that the matter has been decided on the merits and judgment or order passed.

Disposal under Civil Procedure Code

Application for Rejection of Plaint under Order VII Rule 11 of the Code of Civil Procedure can be filed at any stage and the Court has to dispose off the same before proceeding with the trial, the Apex Court has reiterated in  R.k. Roja v U.S. Rayudu and anrs.

Final Orders

Once a final order is passed by the court, the case is said to be disposed of in favour of either of the parties. Such a final order consists of more than one order. They are:-

Judgment Order XX CPC

• A judgement is a final decision about rights and liabilities of the court, on the issues raised before it, pronounced orally on the day of final hearing, or at some other short date.
• In Ibrahimsab vs. Faridabi; ILR 1986 Karnataka 2251, the Karnataka High Court has held as under :
• Section 362 Cr.P.C. contemplates judgment and final order disposing of the case. The expressions ‘final order disposing of the case’ mean a considered order on merits.

Decree (Order XX, rule 6 CPC)

1. A decree contains, more than the judgement and is drawn up within 15 days from the date on which the judgement is pronounced and its copy can also be obtained in the same way, as that of the judgement.
2. There can be various kinds of Decrees, such as:-
   • Decree for recovery of immovable property
   • Recovery of money
   • Decree for delivery of movable property,
   • Decree for possession
   • Decree for specific Performance of contact for the sale etc.

Disposal of the suit at the first hearing (Order XV CPC)

A Court may also dispose of the suit in its very first hearing, on any one of the following grounds: –

• Parties not at issue.
• One of several defendants not at issue.
• Parties at issue.
• Failure to produce evidence

Disposal under Criminal Procedure Code

• According to provisions in Section 256B(4) of CrPc, provide about disposal of case by application for Plea Bargaining. Firstly, after the application for plea bargaining has been filed, the courts examine the accused in the absence of the complainant, to ensure that the application has been filed voluntarily.
• Upon confirmation of voluntary filing of the application by accused, the complainant or the prosecutor have to draw a mutually agreed disposition with the accused for further hearing of disposition.

Section 265C. CrPc: Guidelines for mutually satisfactory disposition.-

• The courts must issue notice to the public prosecutor, investigating public officer and the parties of the case instituted on a police report, to meet up and draw a voluntary satisfactory disposition agreed by all.
• Whereas, when a case is instituted otherwise than on a police report, then the notices are issued to the case parties to discuss and reach on a voluntary satisfactory disposition for the case.

265E. Disposal of the case

Where a satisfactory disposition of the case has been worked out under section 265D, the Court shall dispose of the case in the manner mentioned.

• In V.Subramanian vs The State in October, 2009, the plea bargaining was not made in accordance with the procedure contemplated under the chapter XXI- A and the plea of guilty was made even before the introduction of the said chapter legalising plea bargaining.
• Therefore, the plea of guilty made by the respondents was against Article 21 of the Indian Constitution and that hence the respondents are at liberty to withdraw the said plea of guilty and seek trial of the case.

Conclusion

‘Case Status – Disposed’ means the final order/judgment/decree has been passed by the hon’ble court. It does not mean that the case was quashed.

Please apply for the certified copy of the final order/ judgment/ decree to find out the effect of the Order without a  delay, as such matters are highly time-sensitive.

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