Malahan dalam kes Ganapathy Chettiar v Lum Kum Chum & Ors; Meenachi v Lum Kum Chum & Ors [1981] 2 MLJ 145 Mahkamah Persekutuan menjelaskan berkenaan dengan kesan daripada penghakiman persetujuan tersebut dan bagaimana suatu penghakiman persetujuan itu boleh dipinda. YA Hakim Raja Azlan Shah, Hakim Mahkamah Persekutuan ketika itu menyatakan seperti yang berikut: “This order was therefore made against the wishes of one of Mr. Ariarajah's two clients. Who this person was can now be seen from the appeal lodged by Mr. Ariarajah. She is Meenachi, the wife of the other client of his. But there apparently was no conflict of interests, since this other client has now by another firm of solicitors lodged his own appeal. There are now two appeals, each making the other appellant a respondent, and two sets of appeal records, identical in all respects, even in respect of the grounds of appeal, though not in expression. The order now appealed from obviously varied the consent order. The appeal was therefore grounded almost entirely on the jurisdiction of the court to vary an order which it had made and which had been drawn up and perfected. The question is whether in the circumstances the jurisdiction exercised by the court can be justified. The answer to the question is obvious and, with respect, is so clearly stated in paragraph 2011 of Volume 2 of either the 1976 or the 1979 Supreme Court Practice that we will merely content ourselves with repeating that an order by consent is evidence of the contract between the parties and is binding on all the parties to the order. It may be pleaded as an estoppel: Kinch v Walcott [1929] AC 482. All the more so, in our view, since there is not the slightest question of any mistake as to facts or law. A co-proprietorship of agricultural land which is under cultivation is at best an uneasy proposition and when the conditions pertaining are such that production must suffer, the time has come for the parting of the ways. This could be achieved by one of several ways. One of the co-proprietors could buy out the others, or the land could be partitioned, or the land could be sold either by private treaty or by public auction. This is not unknown to the parties: see the letter dated June 6, 1970 from the then solicitors of the applicant to the other co-proprietors. It was in this understanding of the situation facing them and the alternatives open to them that all the co-proprietors consented to a sale by public auction. Yet in these circumstances and despite the fact that at the hearing his counsel had not voiced any objection on his behalf, Ganapathy Chettiar lodged an appeal from the order made. We could not understand how he could now object and on the facts pertaining to his case, we would have dismissed his appeal on no other consideration. Meenachi's appeal was at least consistent with her objection at the hearing, if not with one of the prayers in her application. Since there had been no mistake on the part of anyone when the consent order for the sale by public auction was made, the only possible way in which this order could be altered would be by the consent of all the parties: Australasian Automatic Weighing Machine Co v Walter 1891 WN 170. Her objection, if taken into consideration by the court, would effectively remove from the court any jurisdiction to make the order. But in making the application she gave that consent. Her husband at the hearing did not seek to withdraw that consent. The learned judge refused Meenachi's application made orally to withdraw the consent in terms of one of the prayers in her joint application and if the learned judge was right, there was therefore before him the consent of all the parties which would effectively give him the jurisdiction to alter the consent order.”