​On April 26, 2025, the Supreme Court of India clarified that Order 43 Rule 1A of the Code of Civil Procedure (CPC) does not create an independent right to appeal against a compromise decree. A party to a suit who disputes the validity of a compromise must first approach the trial court under the proviso to Order 23 Rule 3. Only after the trial court adjudicates on the objection can the party pursue an appeal under Section 96(1) CPC, during which they may invoke Order 43 Rule 1A to contest the compromise.

The Court emphasized that Section 96(3) CPC bars appeals from decrees passed with the consent of parties. Therefore, a party cannot directly appeal a compromise decree without first challenging its validity in the trial court.

This decision reinforces the procedural requirement that objections to compromise decrees must be raised at the trial court level before seeking appellate review.

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