The Supreme Court observed that the principle of res judicata is applicable to future stages of the same process as well as separate subsequent proceedings

The supreme court of India observed in the case of S. RAMACHANDRA RAO vs. S. NAGABHUSHANA RAO & ORS, Res Judicata Is Attracted Not Only in Separate Subsequent Proceedings but Also at Subsequent Stage Of The Same Proceedings. 

The bench of Justices Dinesh Maheshwari and Aniruddha Bose stated that a binding decision cannot be disregarded even under the rule of per incuriam because that rule only applies to precedents and not to the doctrine of res judicata. The bench further rejected the respondent's argument that the appellant's wife is prohibited from requesting permission from the court to represent her husband in her role as a GPA holder because she is an enrolled advocate under Section 32 of the Advocates Act.
The question, in this case, is whether the plaintiff's wife, who is both the General Power of Attorney holder and an enrolled advocate, was qualified to represent him in the aforementioned legal procedures. The Trial Court held that merely for the wife of the appellant being an advocate, there was no prohibition in law for her to act on behalf of her husband as a GPA holder but, it was made clear that she would appear in person as a power agent of her husband and not in her professional capacity as an advocate. The High Court then ruled that a GPA holder could not participate in the proceedings in light of a Division Bench ruling from the same High Court. The order was further challenged. 

It was argued that according to the prior rulings of the High Court, the issue regarding the appellant's wife's presence as his GPA holder was resolved in these proceedings and could not have been reopened at all due to the use of the res judicata concept. This misdirected approach has resulted in the High Court ignoring the doctrine of res judicata and issuing such directions which are opposed to the directions contained in the previous binding orders.

As a result, the court granted appeals and reinstated the Trial Court's decision.

 The apex court further observed an advocate cannot plead or cross-examine, and as regards the impact of Bar Council Rules, particularly on the standards of professional conduct and etiquette