Source: Supreme Court  

Why in News? 

Recently, the bench of Justices Dipankar Datta and Prashant Kumar Mishra held that once a suit is rejected under Order VII Rule 11 of the Code of Civil Procedure, 1908 (CPC) , the appellate court’s jurisdiction is limited to examining the validity of the rejection order and does not extend to directing production of additional documents or evaluating the merits of the case. 

• The Supreme Court held this in the matter of Sri Shrikanth Ns & Ors. v. K. Munivenkatappa & Anr. (2025). 

What was the Background of Sri Shrikanth Ns & Ors. v. K. Munivenkatappa & Anr. (2025) Case ? 

• The dispute concerns a parcel of land bearing Survey No. 11/2 measuring 3 acres 39 guntas situated at Honnakalasapura village, Anekal Taluk, originally granted by the Government of Mysore to one Kurubettappa (father of respondent no. 1/plaintiff) on 19.11.1926. 
• Smt. Marakka, grandmother of the appellants, allegedly purchased the said property through a registered sale deed dated 11.10.1939, with mutation carried out in her name in 1939-40. 
• Respondent no. 1 and his mother initiated multiple proceedings challenging the transaction, including suits for declaration and injunction, applications under the Karnataka Scheduled Castes and Scheduled Tribes (Prohibition of Transfer of Certain Lands) Act, 1978, and criminal complaints alleging document fabrication. 
• The respondent's earlier suits (O.S. No. 181 of 1975, O.S. No. 320 of 1989, O.S. No. 91 of 2010) were dismissed on various grounds including limitation, with appeals and second appeals also being rejected by higher forums. 
• In the present matter, respondent no. 1 filed O.S. No. 434 of 2011 seeking a declaration that the order dated 06.09.2010 passed by respondent no. 2/Tehsildar in RRT No. 87 of 2010 was illegal. 
• The appellants filed an application under Order VII Rule 11(a) & (d) of the Code of Civil Procedure, contending that the respondent could not seek relief without first seeking cancellation of the sale deed dated 11.10.1939. 
• The Trial Court allowed the application and rejected the plaint vide order dated 28.10.2013. 
• Respondent no. 1 then preferred Regular Appeal No. 271 of 2020 against the rejection order and filed I.A. No. 2 under Order XI Rule 14 of CPC seeking direction to the Tehsildar to produce Mutation Register extract No. 5/1939-40. 
• The First Appellate Court allowed the application, which was subsequently affirmed by the High Court, leading to the present appeal before the Supreme Court. 

What were the Court’s Observations? 

• The Supreme Court observed that Order XI Rule 14 of the CPC enables the Court to seek production of documents only during the pendency of a suit, whereas in the present case, the suit had already been dismissed consequent upon the rejection of the plaint. 
• The Court held that the First Appellate Court was not enjoined to decide the merits of the controversy but only to examine the validity of the Trial Court's order rejecting the plaint under Order VII Rule 11 of the CPC. 
• The Apex Court noted that for examining the validity of plaint rejection, the Appellate Court should confine itself to the contents of the plaint and not venture beyond, as no other documents can be seen without first examining the issue concerning rejection of the plaint. 
• The Court observed that the First Appellate Court was unnecessarily influenced by observations made by the Supreme Court while dismissing a Criminal Special Leave Petition, which merely indicated that civil proceedings should be determined on their own merits. 
• The Supreme Court concluded that the order allowing production of the Mutation Register was "totally misconceived and suffers from an error of exercise of jurisdiction" and was beyond the scope of Order XI Rule 14 of the CPC. 
• While setting aside the direction for document production, the Court affirmed the order allowing the respondent to raise additional grounds in the Regular Appeal, finding no illegality therein. 

What is Order XI Rule 14 of CPC ? 

• Order XI, Rule 14 of the Code of Civil Procedure, 1908 confers upon the Court the discretionary power to direct production of documents by any party to the proceedings. 
• The temporal jurisdiction for exercising this power is expressly limited to "during the pendency of any suit," signifying that such direction can only be issued while the suit is actively subsisting before the Court. 
• The documents sought to be produced must satisfy the relevancy criterion by "relating to any matter in question in such suit," establishing a nexus between the document and the justiciable issues. 
• The Court possesses the authority to demand production under oath, thereby ensuring authenticity and veracity of the documents produced pursuant to its direction. 
• The rule vests the Court with further discretion to "deal with such documents, when produced, in such manner as shall appear just," empowering judicial determination regarding admissibility, evidentiary value, and procedural treatment of the produced documents. 
• The provision operates as a procedural mechanism for discovery, aimed at ensuring that all material evidence is brought before the Court for proper adjudication, subject to judicial oversight regarding relevance and propriety.