Further relief based on a declaratory judgment or decree may be granted whenever necessary or proper. The application therefor shall be by petition to a court having jurisdiction to grant the relief. If the application be deemed sufficient, the court shall, on reasonable notice, require any adverse party whose rights have been adjudicated by the declaratory judgment or decree to show cause why further relief should not be granted forthwith.
Rule 87.10.Further Relief May be Granted, When--Procedure.
Part III · Rule 87: Declaratory Judgments · Not amended since adoption on record · Last verified July 22, 2026
In one sentenceA party may seek further relief based on an earlier declaratory judgment by filing a petition, and once the court finds the application sufficient it gives the adverse party notice and a chance to show cause against granting that relief.
Full Text of Rule 87.10
Official Comment
Note: This rule is identical with Section 527.080, RSMo 1959.
Plain-English Summary
A declaratory judgment settles the parties' legal relations, but it does not always end the matter completely. Rule 87.10 lets a party come back to court afterward and seek further relief based on that earlier declaration whenever such relief is necessary or proper.
The process starts with a petition filed with a court that has jurisdiction to grant the relief sought. If the court finds the application sufficient, it does not grant the relief automatically on that basis alone. Instead, it gives the adverse party — the one whose rights were already adjudicated by the declaratory judgment — reasonable notice and requires that party to show cause why the further relief should not be granted right away.
This structure protects both sides: it lets the party who obtained the declaration put it to practical use, while still giving the party bound by the declaration a chance to be heard before the court grants anything beyond the original declaration itself.
Frequently Asked Questions
Can a party get more than just a declaration of rights under Rule 87?
Yes. Rule 87.10 allows a party to seek further relief based on a declaratory judgment whenever such relief is necessary or proper.
How does a party request further relief after a declaratory judgment?
By filing a petition with a court that has jurisdiction to grant the relief sought.
Does the court automatically grant further relief once the petition is filed?
No. If the application is deemed sufficient, the court gives the adverse party reasonable notice and a chance to show cause why the relief should not be granted.
Who has to respond to a request for further relief?
The adverse party whose rights were already adjudicated by the earlier declaratory judgment or decree.
What must the adverse party do when given a show-cause notice?
Explain to the court why the further relief requested should not be granted forthwith.
Source & verification. Rule text and amendment history are
reproduced verbatim from the Missouri State & Federal Court Rules, adopted by the
Supreme Court of Missouri. Last verified July 22, 2026. ·
Official source
Also known as: declaratory judgment actionfurther relief after declaratory judgmentshow cause order declaratory judgmentdeclaratory relief