Repeated amendment applications under Order 6 Rule 17 CPC are barred by principles of res judicata.

The petitioners (defendants) challenged an order dated 18.06.2026 passed by the Trial Court, which rejected their application for amendment of the written statement filed under Order 6 Rule 17 r/w Section 151 of the CPC

Previously, the petitioners had filed a similar amendment application which was rejected; that rejection was challenged in M.P. No. 1234/2026, where the High Court granted liberty to raise grounds after examining plaintiffs at the appropriate stage

The petitioners filed the current application asserting the amendment was necessary to determine the real questions in controversy, noting that respondents filed no reply

The Trial Court rejected the application on the grounds that a similar application had been previously dismissed and the trial had already commenced

1. Whether the Trial Court committed an illegality or perversity in rejecting the application for amendment of the written statement under Order 6 Rule 17 of the CPC

2. Whether the principles of res judicata apply to successive applications for the same amendment relief during trial

The Court applied Order 6 Rule 17 of the CPC, which mandates that all amendments necessary for determining the real question in controversy shall be allowed, provided that no such application be granted after the commencement of trial unless the party demonstrates "due diligence"

Supreme Court precedent in Life Insurance Corporation of India v. Sanjeev Builder Private Limited and Another (2022) 16 SCC 1, which establishes that while courts should be liberal, amendments should be disallowed if they are mala fide, cause irreparable prejudice, or change the nature of the suit, especially after the trial has commenced

The Court observed that the petitioners sought the same relief under Order 6 Rule 17 CPC that had been previously rejected by the Trial Court without the Trial Court granting specific liberty to re-file

The High Court reasoned that the principle of res judicata is impliedly applicable to such successive applications for the same purpose

the Court noted that the trial had already commenced and witnesses had been examined, triggering the restrictive proviso of Order 6 Rule 17

The Court found that the application lacked the requisite showing of due diligence and appeared to be a "dilatory tactic" intended to delay the proceedings

Consequently, the Court held that the Trial Court's decision was legally sound and did not suffer from perversity or impropriety

The Court affirmed that no grounds for interference under Article 227 of the Constitution were made out. Relief denied