Supreme Court Clarifies Scope of Order VII Rule 11 CPC: Plaint Cannot Be Rejected Solely Because One Relief Is Barred
On May 26, 2025, the Supreme Court ruled that a plaint cannot be dismissed in its entirety merely because one of the reliefs sought is legally untenable, provided that other reliefs are maintainable and arise from independent causes of action.
The case involved a dispute where the appellant had purchased agricultural land and later borrowed ₹7.5 crore from the respondent, executing two unregistered documents: an agreement to sell and a power of attorney authorizing the respondent to sell the land. After revoking both instruments, the respondent proceeded to execute registered sale deeds in July 2022, transferring the property to himself and others. The appellant filed a civil suit seeking a declaration that the sale deeds were void, along with possession and injunction reliefs.
The Rajasthan High Court dismissed the suit, treating the reliefs as a single claim and rejecting the plaint solely on the ground that the first relief was invalid, without adjudicating the second relief, which involved a triable issue.
Challenging the High Court’s ruling, the appellant moved to the Supreme Court. The bench, comprising Justices J.B. Pardiwala and R. Mahadevan, observed that the High Court’s wholesale rejection of the plaint, without appreciating that the reliefs claimed flowed from multiple and distinct causes of action—particularly one arising after the revocation of the power of attorney—amounted to an improper application of Order VII Rule 11 CPC. The Court emphasized that selective severance of reliefs is impermissible where different causes of action are independently pleaded and supported by distinct facts.
This judgment reinforces the principle that a plaint should only be rejected under Order VII Rule 11 CPC if, on a plain reading, it discloses no cause of action or falls within the narrowly defined grounds under the provision, such as under-valuation, insufficient court fees, or bar by any law.