Consolidation of applications is inappropriate where the nature of reliefs and the underlying legal issues are distinct, and such requests are identified as dilatory tactics by a party who had previously agreed to a separate adjudication timeline.

Judgment / Order

1. The present writ petition has been filed assailing the order dated 17.04.2026, passed by learned Senior Civil Judge-cum Additional Chief Judicial Magistrate, Chomu, District-Jaipur, whereby the application filed by the defendant-petitioner under Section 151 CPC, seeking consolidation of three pending applications - (i) an application for temporary injunction, (ii) a counter application for temporary injunction, and (iii) an application filed by the plaintiff-respondent under Section 151 CPC for restoration of status as it existed on the date of filing of the suit, was rejected.

2. Learned counsel for the petitioner, at the outset, submits that it is a settled principle of law that all applications seeking similar relief ought to be decided together to avoid contradictory orders. Learned counsel further submits that the application filed by the plaintiff-respondent under Section 151 CPC, seeking restoration of status as it existed on the date of filing of the suit, ought to have been decided along with the pending temporary injunction applications.

3. Learned counsel for the petitioner also submits that the third application under Section 151 CPC, filed by the plaintiff-respondent, was not maintainable before the learned Trial Court, as by way of the said application, the plaintiff-respondent sought for restoration of status quo ante of the disputed land as existing on date of filing of the suit.

4. Learned counsel for the petitioner further submits that in case of disobedience of an injunction order, the only remedy available is to file an application under Order 39 Rule 2A CPC, and the Court cannot independently pass an order under Section 151 CPC. Therefore, the learned Trial Court has committed gross illegality in passing the impugned order dated 17.04.2026.

5. Per contra, learned counsel for the respondents submits that an interim order dated 17.10.2025 was passed by the learned Trial Court directing the defendant-petitioner to maintain status quo regarding the site and records of the disputed property.

6. Learned counsel for the respondent submits however, that after the passing of the order dated 17.10.2025, the defendant-petitioner raised certain constructions, necessitating the filing of an application under Section 151 CPC.

7. Learned counsel for the respondent further submits that the reliefs sought in the temporary injunction application and the counter temporary injunction application are entirely different from the relief sought in the application filed under Section 151 CPC. He, therefore, submits that the temporary injunction applications and the application under Section 151 CPC are required to be decided separately.

8. Learned counsel for the respondents also submits that the petitioner had earlier approached this Court in S.B. Civil Writ Petition No. 5373/2026 titled as ‘Harinarayan S/o Rameshwar Lal vs M/s Mahalakshmi Minerals & Ors.’ (decided on: 24.03.2026), wherein the petitioner challenged the rejection of an amendment sought in the reply to the application under Section 151 CPC.

9. Learned counsel for the respondent submits that therein it was brought to the notice of the Court that the facts sought to be introduced by way of amendment were already part of the pleadings. Both parties agreed that the application under Section 151 CPC could be decided on the existing pleadings, including written statement and counter claim irrespective of the rejection of the amendment under Order 6 Rule 17 CPC.

10. Learned cou