Madanayake vs. Gnanawansa – sllr 2019 volume 1 page 353

The case between Madanayake (plaintiff) and GnanawanSA and others (defendants) addressed whether an ex parte judgment under Section 86(2) of the Civil Procedure Code could be set aside based on a default purging application, with particular attention to the required standard of proof (“reasonable grounds” for default) and the impact of a defendant’s unsound mind on the legitimacy of legal proceedings. It was held that where a defendant is shown to be of unsound mind, proceedings against such a defendant are invalid absent the appointment of a guardian. The principle was reaffirmed that the inquiry under Section 86(2) requires a liberal and subjective approach, focusing on reasonable grounds rather than strict standards. The decision relied on the Civil Procedure Code and relevant case law,