Inapplicability of Collateral Challenges against Satisfied Decrees

The doctrine of finality of judicial determinations prohibits parties from mounting collateral attacks on executed decrees through indirect procedural applications. When a decree-holder obtains a final decree declaring right, title, and interest over a specific scheduled property and successfully pursues execution proceedings resulting in demarcated delivery of possession, the resulting order of satisfaction enjoys absolute judicial sanctity. A judgment-debtor who failed to raise contemporaneous objections during the demarcation and delivery process cannot subsequently attempt to subvert the execution by filing an independent application alleging boundary discrepancies or mistaken plot identity. Permitting such collateral proceedings disrupts settled rights, subjects the successful litigant to indefinite uncertainty, and frustrates the fruits of litigation. The court is duty-bound to enforce procedural discipline by rejecting any application that seeks to circumvent the finality of an executed decree. (Ananda Chandra Panda (Dead) Through LRs. Vs The Collector, Keonjhar & Another | 2026 INSC 91)