The Supreme Court of India has held that a civil plaint cannot be rejected in its entirety merely because one of the prayers or reliefs sought is legally untenable, reaffirming the principle that where distinct and valid causes of action are pleaded, the suit must proceed to trial. The ruling came in Vinod Infra Developers Ltd. v. Mahaveer Lunia & Ors. (Civil Appeal No. 7109 of 2025), wherein the Court reversed the Rajasthan High Court’s decision that had rejected the plaint under Order VII Rule 11 of the Code of Civil Procedure, 1908 (“CPC”).
The two-judge Bench comprising Justices J.B. Pardiwala and R. Mahadevan observed that the High Court committed a jurisdictional error by treating the second cause of action in the suit as “academic” and rejecting the plaint in its entirety without considering the presence of triable issues.
Background of the Case
The appellant, Vinod Infra Developers Ltd., claimed ownership of 18 bighas and 15 biswas of agricultural land in Village Pal, Jodhpur, purchased in 2013. In May 2014, the company borrowed ₹7.5 crore from Respondent No.1, Mahaveer Lunia, and in connection with the loan, executed an unregistered power of attorney and agreement to sell in his favour. These documents were later revoked by board resolutions dated May 24 and May 27, 2022.
Despite the revocation, Respondent No.1 executed sale deeds dated July 13 and 14, 2022, in his favour and in favour of Respondent Nos.2 to 4, which were registered on July 19, 2022. Based on these documents, the respondents’ names were mutated in the revenue records.
Vinod Infra Developers Ltd. filed a suit in the District Court, Jodhpur, seeking declarations that the sale deeds were void, recovery of possession, and a permanent injunction. Respondents filed an application under Order VII Rule 11 CPC to reject the plaint, which was dismissed by the trial court. However, the High Court allowed a revision petition and rejected the plaint in its entirety.
Arguments Before the Supreme Court
Counsel for the appellant argued that the High Court erred in rejecting the plaint wholesale, despite it disclosing triable issues concerning the sale deeds executed after the revocation of the power of attorney. They emphasized that even if one cause of action survives, the plaint cannot be rejected entirely, citing Central Bank of India v. Prabha Jain (2025 INSC 95).
It was further contended that the unregistered documents could not convey title under Sections 17, 23, and 49 of the Registration Act, 1908, and that the revocation of authority prior to the execution of sale deeds rendered the transactions void. The appellant also relied on Suraj Lamp & Industries (P) Ltd. v. State of Haryana [(2012) 1 SCC 656], which held that unregistered agreements to sell or powers of attorney do not convey title.
In response, the respondents argued that the transaction was a genuine sale, not a mortgage, and that the appellant had no cause of action, particularly as the documents were executed in 2014 and acted upon. They also contended that issues of khatedari rights fall under the exclusive jurisdiction of revenue courts under Section 207 of the Rajasthan Tenancy Act, 1955.
Supreme Court’s Analysis
The Court reiterated the settled legal principle that the power to reject a plaint under Order VII Rule 11 CPC must be exercised only where the suit is manifestly barred by law, fails to disclose any cause of action, or suffers from incurable defects on the face of the pleadings.
It found that the appellant had raised distinct causes of action — notably, the execution and registration of sale deeds after the revocation of power of attorney — which clearly warranted a full trial. The Court observed:
“The High Court’s wholesale rejection of the plaint, without appreciating that the reliefs claimed flowed from multiple and distinct causes of action… amounts to an improper application of Order VII Rule 11 CPC.”
The Court relied on its own ruling in Central Bank of India to reaffirm that a plaint cannot be partially rejected; hence, if one cause of action survives, the plaint must proceed.
On the question of title, the Court emphasized that unregistered documents such as the power of attorney and agreement to sell, especially when executed in 2014 and never registered, could not form the basis of valid transfer of title. It cited multiple precedents, including S. Kaladevi v. V.R. Somasundaram [(2010) 5 SCC 401] and Suraj Lamp (supra), to hold that such documents are inadmissible for purposes of ownership, and cannot be relied upon unless in a suit for specific performance — which, in this case, was never filed.
The Court also rejected the applicability of Section 207 of the Rajasthan Tenancy Act, noting that the issues raised in the plaint pertained to ownership and title, which fall within the jurisdiction of civil courts.
Decision
Holding that the High Court erred in rejecting the plaint at the threshold, the Supreme Court allowed the appeal and restored the order of the trial court. It directed that the plaint be reinstated on the file of the District Court, Jodhpur, which shall proceed with the suit on merits.
“Accordingly, 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.
