In a significant ruling, the Supreme Court of India has clarified that High Courts cannot reject a plaint using their powers under Article 227 of the Constitution. The Court emphasized that this provision grants only supervisory jurisdiction, not the power to bypass the functions of lower courts.
The judgment came in the case K. Valarmathi vs Kumaresan, where the Madras High Court had rejected a plaint by invoking the Prohibition of Benami Property Transactions Act. Challenging this move, the petitioner approached the Supreme Court.
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A bench comprising Justice PS Narasimha and Justice Joymalya Bagchi set aside the High Court’s decision. The Court explained that while Article 227 allows supervision over lower courts and tribunals, it does not authorize a High Court to take over the role of the trial court.
"Power of the High Court under Article 227 is supervisory and is exercised to ensure courts and tribunals under its supervision act within the limits of their jurisdiction conferred by law,"
– Justice Joymalya Bagchi
The judgment stressed that such power must be used rarely and only when there are clear errors causing serious injustice. It cannot be used to replace original jurisdiction or overrule legal remedies available under the Civil Procedure Code (CPC), 1908.
The Court pointed to Order VII Rule 11 of the CPC, which specifically lists the grounds on which a trial court may reject a plaint. According to the Supreme Court, any such rejection becomes a "deemed decree", which can be challenged through an appeal under Section 96 of the CPC.
"This statutory scheme cannot be upended by invoking supervisory jurisdiction of the High Court under Article 227 to entertain a prayer for rejection of plaint,"
– Supreme Court
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The top court criticized the High Court's action in this case, noting that it had essentially acted as the trial court. This move, the Court said, took away the petitioner’s right to appeal, which would have existed had the decision come from a lower court.
"Short-circuiting of procedure to reach hasty outcomes is an undesirable propensity... Such impulses subvert certainty and consistency in law and need to be discouraged,"
– Supreme Court
The Court highlighted that procedural law is essential for upholding the rule of law. Bypassing procedures not only weakens legal safeguards but also undermines consistency in legal processes.
The Court referred to earlier decisions, especially the 2014 judgment in Jacky v. Tiny @ Antony & Ors, which clearly held that plaints cannot be rejected under Articles 226 or 227. It also distinguished the 2022 decision in Frost (International) Ltd. v. Milan Developers, where a plaint was rejected only in revisional jurisdiction, not directly under Article 227.
Appearing Counsel:
- Advocate M. Gireesh Kumar represented the appellant.
- Senior Advocate R. Baskaran appeared for the respondent.
- Senior Advocate Mr. V. Prabhakar assisted the court as Amicus Curiae.
