The Supreme Court of India recently clarified a crucial point under Order VII Rule 11 of the Code of Civil Procedure, 1908 (CPC): a plaint cannot be entirely rejected if at least one relief claimed in it is maintainable. This ruling preserves a plaintiff’s right to have a claim heard, even if some of the reliefs asserted are weak or untenable.
The Facts Behind the Case
• The plaintiff (appellant), Boyenepally Srijayavardhan, entered into an agreement to sell two agricultural land parcels in Telangana with a seller (Respondent No. 6) in August 2018. Consideration was ₹4 crores; payments totaling ₹12 lakhs were made in advance.
• The agreement, however, did not stipulate a timeline for paying the rest of the consideration.
• Later, the seller took steps (via a compromise decree) that effectively transferred rights in those lands to third parties who had earlier instituted suits with injunctive relief.
• The appellant filed a suit for specific performance of the original agreement, delivery of possession, and cancellation of the compromise decrees.
What the Lower Courts Did
• Respondents applied under Order VII Rule 11 CPC for the rejection of the plaint, arguing (among other things) that there was no privity of contract with some defendants, that some reliefs were barred, and that some claims disclosed no cause of action.
• The trial court accepted this, rejected the plaint, holding that it lacked necessary pleadings.
• The Telangana High Court upheld the rejection, albeit on different grounds: it held the suit was barred under certain provisions (e.g. Section 19 of the Specific Relief Act, 1963, and Order XXIII Rule 3-A CPC), and that there was no cause of action against some of the defendant parties.
Supreme Court’s Judgment & Legal Principle
The Supreme Court reversed the lower courts’ decisions, laying down an important principle:
Even if some reliefs claimed by the plaintiff are not maintainable, if there is at least one relief that is maintainable (properly pleaded), the entire plaint cannot be rejected under Order VII Rule 11.
Key highlights:
• The Court found that the claim for specific performance against the original seller was properly made out and maintainable.
• The fact that there might be defects or bar in respect of other reliefs (e.g. cancellation of compromise decrees) does not justify rejection of the entire plaint at the preliminary stage.
• Also, rejection of the plaint deprived the plaintiff of an alternative relief (refund of the advance payment), which had been pleaded.
• Thus, the Supreme Court ordered that the suit proceed to trial, allowing issues to be framed, evidence to be led, and all parties to present their case on the merits.
Broader Implications
This ruling reinforces a protective principle for plaintiffs: courts should be cautious in rejecting a plaint in entirety unless no claim at all is maintainable. Some consequences:
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Pleading care matters: Plaintiffs must ensure that at least one of their claims (or reliefs) is validly and well-pleaded. Even if others are doubtful, that does not sink the whole plaint.
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Defendants’ relief by demur applications is limited: Since Order VII Rule 11 deals with demurring the plaint (i.e. rejecting without trial), this decision limits its use. A defendant cannot avoid trial simply by attacking certain reliefs, if one relief holds.
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Court’s early-stage scrutiny must be balanced: Lower courts must more carefully examine if there is any relief that can stand; if yes, rejection ought not to follow. Issues such as cause of action, maintainability, privity etc. must be evaluated in light of all reliefs claimed.
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Conclusion
The Supreme Court’s ruling underlines a fundamental principle: the procedural law (CPC) should not be used to prematurely block deserving claims. If a plaint contains even one well-pleaded claim or relief, the whole case deserves to be heard on merits, regardless of the weaknesses or doubts about other reliefs. For plaintiffs, it’s a reminder to plead carefully. For courts, it’s a guide to ensure fairness and avoid justice being denied even before trial.
