The Orissa High Court has recently held that the principle of res judicata, as provided under Section 11 of the Code of Civil Procedure (CPC), is not applicable to execution proceedings under Order XXI of the CPC as it is a 'self-contained' and 'independent Order'.Justice Ananda Chandra Behera held that non-applicability of res judicata is a fundamental rule of civil law. In his words –“It...