A Plaint Cannot Be Rejected In Its Entirety Merely Because One Of The Prayers Or Reliefs Sought Is L

Supreme Court: Civil Suit Cannot Be Rejected Entirely If One Valid Cause of Action Exists

Vinod Infra Developers Ltd. v. Mahaveer Lunia & Ors., Civil Appeal No. 7109 of 2025

 

In a significant reaffirmation of procedural fairness, the Supreme Court of India has ruled that a civil plaint cannot be dismissed in its entirety merely because one of the reliefs sought is legally untenable. The ruling, delivered by Justices J.B. Pardiwala and R. Mahadevan, underscores that where valid and distinct causes of action exist, the matter must go to trial.

 

Case Background

 

Vinod Infra Developers Ltd. had purchased agricultural land in Village Pal, Jodhpur in 2013. In 2014, the company borrowed Rs. 7.5 crore from Mahaveer Lunia and executed an unregistered power of attorney and agreement to sell in his favour. These were later revoked by board resolutions in May 2022. Despite this, sale deeds were executed by the respondent in July 2022, leading to a mutation of names in revenue records.

 

Vinod Infra challenged these actions in the District Court, seeking to declare the sale deeds void, recover possession, and obtain a permanent injunction. Though the trial court refused to reject the plaint, the Rajasthan High Court allowed a revision petition and dismissed the suit entirely under Order VII Rule 11 of the CPC.

 

Arguments Before the Apex Court

 

The appellant's counsel contended that the High Court overstepped by rejecting the entire plaint without recognizing the triable issues—particularly the execution of sale deeds after revocation of authority. Relying on Central Bank of India v. Prabha Jain, it was argued that even if some reliefs are weak, the plaint should proceed if at least one valid cause exists.

 

They also emphasized that unregistered documents like power of attorney and agreements to sell cannot transfer title, citing Suraj Lamp & Industries v. State of Haryana and other precedents.

 

The respondents, in contrast, maintained that the transaction was genuine and fully acted upon. They also claimed that matters of khatedan rights should be dealt with by revenue courts under Section 207 of the Rajasthan Tenancy Act.

 

Supreme Court's Findings

 

The Court found merit in the appellant’s position. It clarified that Order VII Rule 11 CPC should only be applied in clear-cut cases where the suit is barred by law or discloses no cause of action. The existence of distinct claims—particularly concerning the post-revocation sale deeds—meant that triable issues were present.

 

The Bench held that the High Court had committed a "jurisdictional error" by treating one cause of action as "academic" and rejecting the entire plaint.

 

It also reaffirmed that unregistered documents do not convey title and cannot be the basis for ownership unless in a suit for specific performance—which was not the case here.

 

The Court dismissed the applicability of the Rajasthan Tenancy Act, holding that issues of ownership and title fall squarely within the civil court’s jurisdiction.

 

Final Verdict

 

The Supreme Court set aside the High Court’s order and restored the trial court’s decision, allowing the suit to proceed.

 

> “The appeal is allowed. The impugned order of the High Court is set aside, and the order of the Additional District Judge is restored,” the Court concluded.

 

 

 

This judgment serves as a reminder that civil disputes involving complex questions of fact and title must be adjudicated through trial—not dismissed prematurely

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