Introduction
In a landmark judgment delivered on April 29, 2025, in K. Valarmathi & Ors. v. Kumaresan [Civil Appeal arising from SLP (C) No. 21466 of 2024], the Court clarified the contours of supervisory jurisdiction under Article 227 of the Constitution. At the heart of the matter was whether the High Court could reject a plaint in exercise of this supervisory jurisdiction, bypassing procedural safeguards provided under the Civil Procedure Code (CPC), 1908.
Factual Background
The appellants, being the wife and daughters of one Kathiresan (deceased), filed a civil suit seeking declaration of title and injunction over agricultural land originally purchased in the name of the respondent, who is Kathiresan’s nephew. The purchase was allegedly made by Kathiresan using his own funds but in the respondent’s name based on astrological advice. Kathiresan retained possession during his lifetime, and the appellants continued possession post his demise.
Upon disputes arising between Kathiresan’s heirs and his sisters regarding ownership, the respondent initiated negotiations for sale of the suit land. Consequently, the appellants filed O.S. No. 1087 of 2018 for declaration and injunction. A parallel suit, O.S. No. 201 of 2018, pertained to other properties purchased similarly.
The respondent sought rejection of the plaints under Article 227 of the Constitution through petitions before the High Court. The High Court, by order dated July 11, 2024, rejected the plaint in O.S. No. 1087 of 2018, deeming it barred under the Prohibition of Benami Property Transactions Act, 1988 (“Benami Act”).
Legal Issues
The key legal issue was:
Whether the High Court can exercise supervisory jurisdiction under Article 227 of the Constitution to reject a plaint on the ground that it is barred by law.
Arguments Advanced
For the Appellants:
- The High Court overstepped its jurisdiction under Article 227, which is supervisory and not original.
- The power to reject a plaint vests solely with the trial court under Order VII Rule 11 of CPC.
- The High Court’s act usurped original jurisdiction and deprived the appellants of their statutory right to appeal.
For the Respondent:
- Supported the High Court’s decision, contending the suit was clearly barred under the Benami Act and the plaint deserved rejection.
- Justified invocation of Article 227 for speedy disposal of a legally untenable claim.
Amicus Curiae Submissions:
- Emphasised that Article 227 jurisdiction cannot be used to override procedural safeguards embedded in the CPC.
- Cautioned against substituting original jurisdiction of trial courts with supervisory powers.
Reasoning of the Court
The Court reaffirmed that Article 227 confers supervisory jurisdiction intended only to correct jurisdictional errors, not to exercise original adjudicatory powers. It emphasised that:
- Article 227 cannot be invoked to short-circuit the self-contained scheme of the CPC.
- Rejection of plaint under Order VII Rule 11 CPC is a deemed decree, appealable under Section 96 CPC.
- High Courts cannot usurp this original jurisdiction, thereby denying parties their appellate remedy.
The judgment drew support from Virudhunagar Hindu Nadargal Dharma Paribalana Sabai v. Tuticorin Educational Society, (2019) 9 SCC 538, cautioning against use of Article 227 when statutory remedies exist.
Additionally, the Court analysed Frost (International) Ltd. v. Milan Developers, (2022) 8 SCC 633, but distinguished it on the ground that in Frost, the High Court exercised revisional jurisdiction—not supervisory jurisdiction—to reverse a trial court order. In contrast, the High Court in the present case exercised original jurisdiction, bypassing the trial court entirely.
Citing Jacky v. Tiny @ Antony, (2014) 6 SCC 508, the Court reiterated that constitutional powers under Articles 226/227 cannot be used to challenge a plaint, even where maintainability is in question.
Final Holding
The Court held that:
- The High Court’s action amounted to an unauthorised exercise of original jurisdiction.
- Procedural safeguards and statutory rights of appeal cannot be bypassed.
- The impugned order dated July 11, 2024, rejecting the plaint was set aside.
- The respondent was given liberty to pursue remedies before the trial court under the CPC.
Conclusion
This judgment underscores the sanctity of procedural law and the limits of supervisory jurisdiction under Article 227. It acts as a strong precedent against judicial overreach and reinforces that even efficiency cannot trump procedural integrity. The Court’s reasoning upholds not only legal correctness but also systemic fairness.
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FAQs:
Q1: What was the core issue in the Valarmathi v. Kumaresan case?
The key issue was whether the High Court could reject a civil plaint under Article 227, bypassing the procedural scheme under the Civil Procedure Code.
Q2: Can the High Court use Article 227 to reject plaints?
No. The Court held that supervisory jurisdiction under Article 227 cannot substitute the original jurisdiction of trial courts to reject plaints.
Q3: What legal rights were upheld in this decision?
The judgment reinforced parties’ right to have their plaint adjudicated by the trial court and their statutory right to appeal under Section 96 CPC.