Indian courts have gradually refined their interpretation of the rule against splitting of causes of action under Order II Rule 2 of the Civil Procedure Code to balance procedural efficiency with substantive justice. Earlier judgments such as Mohd. Khalil v. Mahbub Ali Mian (1949) treated the rule strictly, barring subsequent suits if any part of the cause of action was omitted. Over time, however, the judiciary adopted a more nuanced approach, recognizing exceptions for genuinely distinct causes of action or evolving rights. The turning point came through cases like Gurbux Singh v. Bhooralal (1964), State of Maharashtra v. National Construction Co. (1996), and Sonic Surgical v. National Insurance Co. (2010), which collectively emphasized that the bar applies only when both suits are founded on identical essential facts. Recent decisions—Cuddalore Powergen Corporation Ltd. v. Chemplast Cuddalore Vinyls Ltd. (2025), LIC of India v. Sanjeev Builders Pvt. Ltd. (2022), and Tarsem Singh v. Sukhminder Singh (2008)—have further clarified that procedural law should not stifle legitimate claims where fresh causes or obligations arise. This evolution reflects the courts’ consistent effort to uphold judicial integrity while allowing flexibility for efficient and fair adjudication.
