Plaint Cannot Be Rejected If Even One Relief Is Maintainable
September 11, 2025
Bench Restores Telangana Land Dispute Suit, Clarifies Scope of Order VII Rule 11 CPC
Ruling Protects Plaintiffs’ Rights When Multiple Reliefs Are Sought in a Single Case
By Our Legal Reporter
New Delhi: September 11, 2025: In a significant judgment that will impact civil litigation across India, the Supreme Court has ruled that a plaint (civil suit) cannot be rejected under Order VII Rule 11 of the Code of Civil Procedure (CPC) if the plaintiff is entitled to even one of the reliefs claimed. The decision reinforces the principle that courts must allow a case to proceed to trial if any part of the claim is legally sustainable.
The ruling came from a bench of Justice Vikram Nath and Justice Sandeep Mehta, which set aside orders of the Telangana High Court and a trial court that had dismissed a suit for specific performance at the preliminary stage. The apex court restored the suit for trial, emphasising that partial rejection of a plaint is impermissible under the law.
Background of the Dispute
The case arose from an agreement to sell dated August 23, 2018, between the appellant, Sri Boyenepally Srijayavardhan, and the original seller (Respondent No. 6). The agreement covered two parcels of agricultural land in Ranga Reddy district, Telangana, for a total price of ₹4 crore. The buyer paid ₹12 lakh in advance in three instalments via cheques.
The agreement did not specify a deadline for paying the balance. In May 2023, the appellant issued a legal notice to the seller to execute the sale deed. However, he discovered that the seller had, in January 2023, entered into a compromise decree with other parties (Respondents 1 to 5 and another defendant) in two old injunction suits filed in 2014. This compromise effectively transferred ownership rights to those parties, undermining the appellant’s agreement.
The appellant then filed a suit for specific performance of the 2018 agreement, seeking:
- Execution of the sale deed and delivery of possession.
- Cancellation of the compromise decrees.
- Alternative relief for refund of the advance amount.
Lower Courts’ Decisions
Respondents 1 to 5 applied under Order VII Rule 11 CPC to have the plaint rejected, arguing:
- There was no privity of contract between them and the appellant.
- A separate suit to cancel a compromise decree was barred by Order XXIII Rule 3A CPC.
The trial court accepted their plea and rejected the plaint in October 2023, holding that the reliefs sought were not maintainable.
The Telangana High Court upheld the rejection in January 2025, citing Section 19 of the Specific Relief Act, 1963 and Order XXIII Rule 3A CPC. It concluded that the plaint disclosed no cause of action against several defendants.
Supreme Court’s Analysis
The Supreme Court disagreed with both lower courts. It held that:
- The suit clearly disclosed a cause of action for specific performance against the original seller (Respondent 6), independent of the claims against other defendants.
- Even if the relief for cancellation of the compromise decree was legally contentious, the claim for specific performance was maintainable and should be tried.
- Rejecting the plaint entirely also deprived the appellant of his alternative claim for a refund of the advance amount.
The bench noted that the compromise decree arose from suits originally filed only for permanent injunction, not for declaration of title. It also observed that the seller had initially denied the ownership claims of the other parties, calling their documents “forged and fabricated,” but later conceded their ownership in the compromise. Whether this was collusive or unlawful could only be decided after a full trial.
Key Legal Principle Reaffirmed
Justice Mehta, writing the order, reiterated:
“It is a well-settled principle of law that where out of many reliefs claimed in the plaint, the plaintiff is found entitled to even one of them, the plaint cannot be rejected under Order VII Rule 11 CPC.”
The court cited earlier rulings, including:
- Sejal Glass Limited v. Navilan Merchants Private Limited – holding that if a plaint survives against certain defendants or properties, it must proceed to trial.
- Central Bank of India v. Prabha Jain – emphasising that partial rejection of a plaint is not permissible.
The bench stressed that Order VII Rule 11 CPC is meant to weed out cases with no cause of action or those barred by law, but it cannot be used to dissect a plaint and reject parts of it while ignoring maintainable claims.
Impact of the Judgment
This ruling will have far-reaching consequences for civil litigation:
- Protection for Plaintiffs – Litigants will not lose their entire case if at least one relief is valid.
- Clarity for Trial Courts – Judges must examine whether any relief is maintainable before rejecting a plaint.
- Curb on Technical Dismissals – Prevents defendants from using procedural objections to derail cases prematurely.
Legal experts say the decision strengthens access to justice by ensuring that genuine disputes are decided on evidence rather than being dismissed on technical grounds at the outset.
Next Steps in the Case
The Supreme Court allowed the appeal, set aside the orders of the High Court and trial court, and directed the trial court to proceed with the suit in accordance with law. The case will now return to the trial stage, where evidence will be recorded and issues framed on:
- The validity of the 2018 agreement to sell.
- Whether the compromise decree was collusive.
- The appellant’s entitlement to specific performance or refund.
Understanding Order VII Rule 11 CPC
Order VII Rule 11 of the CPC allows a court to reject a plaint if:
- It does not disclose a cause of action.
- The relief claimed is barred by law.
- The plaint is undervalued or insufficiently stamped.
However, as reaffirmed by the Supreme Court, this provision applies only when the plaint as a whole is defective. If any part of the claim is maintainable, the suit must proceed.
Conclusion
The Supreme Court’s ruling in Sri Boyenepally Srijayavardhan v. Respondents is a strong reminder that procedural rules should not be used to shut the doors of justice when a legitimate claim exists. By clarifying that even one maintainable relief can save an entire plaint from rejection, the court has reinforced the principle that disputes should be resolved on merits, not dismissed on technicalities.
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