Key Points:

1. An order dismissing a counter-claim becomes a final adjudication and attains the status of a decree, which conclusively determines the rights of the parties involved (!) (!) .

2. Such a decree can only be challenged through an appeal; it cannot be challenged under the constitutional jurisdiction of Article 227 of the Constitution of India (!) .

3. A counter-claim filed by a defendant in a suit is in the nature of a cross-suit, and even if the main suit is dismissed, the counter-claim remains alive for adjudication as an independent claim (!) .

4. The scheme of the Civil Procedure Code (CPC) mandates that a counter-claim shall have the same effect as a cross-suit and must be finally adjudicated within the same suit, with the court required to pronounce a final judgment on both the original claim and the counter-claim (!) .

5. When a counter-claim is adjudicated and dismissed on merits, the order has the effect of a decree, and the rights of the parties with respect to that claim are conclusively settled (!) (!) .

6. An order that finally determines the rights of the parties in respect of a counter-claim, especially one that is barred by procedural principles such as Order 2, Rule 2 of CPC, is a substantive adjudication and thus has the status of a decree (!) (!) .

7. Such a decree can be challenged only through an appeal, and not through supervisory or revisional jurisdiction under Article 227 or Section 115 of CPC (!) (!) .

8. The challenge to an order that has the status of a decree must be made before the proper appellate forum, and failure to do so renders the order unassailable under constitutional or revisional jurisdiction (!) .

9. The order dismissing the counter-claim, after adjudication on merits, is final and conclusive, and the rights of the parties are settled accordingly (!) (!) .

10. The exercise of revisional or supervisory jurisdiction to unsettle such an order is not permissible; instead, the appropriate remedy is to prefer an appeal (!) (!) .

11. The order passed by the trial court, which has the status of a decree, cannot be invalidated or set aside under Article 227 of the Constitution, as that jurisdiction is not meant for re-evaluating substantive rights but for correcting procedural errors (!) .

12. The appellate process is the proper and exclusive remedy for challenging final orders that have the effect of a decree, ensuring the finality and conclusiveness of such judgments (!) .

These points collectively emphasize that orders finalizing and adjudicating counter-claims on merits are considered decrees, which must be challenged through appeals, not supervisory or revisional jurisdiction.