Mallika De Silva v. Gamini De Silva – sllr 1999 volume 1 page 085

In the case between Mallika de Silva and Gamini de Silva, the court addressed whether an interim injunction may be granted to a party who has not sought any substantive relief or made a counter claim under Section 54 of the Judicature Act, and whether an order that is ex facie bad in law may be quashed by revision in the absence of an appeal. The holding established that an interim injunction can only be granted as auxiliary to substantive relief—in the absence of a substantive claim or counter claim, a party is not entitled to seek such an injunction under Section 54(2). It was further determined that ex facie erroneous judicial orders may be revised even if appellate remedies are unavailable. The decision reaffirmed the auxiliary nature of injunctive relief under the Judicature Act, refe