Khurana Brothers vs Anand Bardhan Principal Secretary 2025 INSC 1240-Doctrine of Merger
Doctrine of merger- The doctrine of merger is not a doctrine of rigid and universal application and it cannot be said that wherever there are two orders, one by inferior court or tribunal and the other by superior court or tribunal, passed in an appeal or revision, there is fusion or merger of two orders irrespective of the subject matter of the appellate or revisional order and the scope of appeal or revision contemplated by the particular statute- application of the doctrine of merger depends on the nature of the appellate or revisional order in each case and the scope of the statutory provisions conferring the appellate or revisional jurisdiction. (Para 7)
Case Info
- Case name: M/S Khurana Brothers v. Anand Bardhan Principal Secretary & Anr.
- Neutral citation: Not provided in the document.
- Coram: Justice Manoj Misra; Justice Ujjal Bhuyan.
- Judgment date: 14 October 2025 (New Delhi).
Caselaws and citations
- State of Madras v. Madurai Mills Co. Ltd., 1966 SCC OnLine SC 140; AIR 1967 SC 681.
#SupremeCourt clarifies scope of Doctrine Of Merger: https://t.co/sjsw070wbG pic.twitter.com/8W4pgH3Vep
— CiteCase 🇮🇳 (@CiteCase) October 16, 2025


