The essential-facts test helps determine whether two claims arise from the same cause of action by examining whether the material facts needed to establish each claim are identical. According to judicial precedents and the principles under Order II Rule 2 CPC, if both claims rely on the same set of essential facts—representing the same transaction, right, and breach—then they form one cause of action. However, if each claim requires distinct evidence or originates from different legal obligations, they are treated as separate actions. The Supreme Court in Mohd. Khalil v. Mahbub Ali Mian and reaffirmed in later decisions such as Sonic Surgical v. National Insurance Co. emphasized that the real test lies not in the form of pleading but in the substance of the facts and proof required. Courts have thus held that even when underlying circumstances overlap, claims may be considered independent if they involve separate rights, transactions, or breaches—ensuring fairness without conflating distinct legal grievances.
