S. Rankiri vs Kiri Hattena – clr volume 1 page 086

In S Rankiri v. Kiri Hattena, the court addressed whether the dismissal of an earlier proceeding for non‐maintenance of a child—due to insufficient evidence of paternity—constitutes a decision on the merits which acts as res judicata, thus barring a subsequent application under Maintenance Ordinance No. 19 of 1889. It was held that such a dismissal does have preclusive effect and operates as a bar to further action on the same facts, reaffirming the principle that a final decision on the merits is conclusive between parties as to the issues determined. This decision relied on established precedents and interpretations, including Regina v. Glynne and 5 S.C.C., emphasizing that proceedings under the Ordinance, being criminal or quasi-criminal in nature, do not create continuing civil liabili