Source: Supreme Court  

Why in News? 

Recently, the bench of Justice PS Narasimha and Justice Joymalya Bagchi   held that a High Court cannot reject a plaint under its supervisory jurisdiction under Article 227 of the Constitution of India, 1950 (COI), as it cannot usurp the functions of the trial court. 

• The Supreme Court held this in the case of K. Valarmathi v. Kumaresan (2025). 

What was the Background of K. Valarmathi v. Kumaresan (2025) Case? 

• The appellants are the legal heirs (wife and daughters) of one Kathiresan (deceased). 
• Kathiresan, during his lifetime, purchased certain nanja lands with his own funds but registered them in the name of the respondent (his nephew) based on astrological advice. 
• Kathiresan maintained possession of the suit land during his lifetime, and after his death, the appellants claim to have continued possession. 
• Following Kathiresan's death, disputes emerged between the appellants and Kathiresan's sisters regarding ownership of the suit land and other business interests. 
• The respondent, who is the son of one of Kathiresan's sisters, initiated negotiations for the sale of the suit land. 
• This prompted the appellants to institute O.S. No. 1087 of 2018 seeking a declaration of title and consequential injunction against the respondent from encumbering the suit land. 
• The appellants also filed another suit (O.S. No. 201 of 2018) concerning other lands purchased by Kathiresan in the name/joint name of other family members. 
• The respondent approached the High Court under Article 227 of the Constitution seeking rejection of the plaint in both suits. 
• The High Court, through the impugned order, rejected the plaint in O.S. No. 1087 of 2018 on the ground that it was barred by the Prohibition of Benami Property Transactions Act, 1988. 
• For the other suit (O.S. No. 201 of 2018), the High Court held it was not barred under the Benami Act and declined relief. 
• The appellants challenged the jurisdiction of the High Court to reject the plaint in the exercise of its supervisory powers under Article 227 of the Constitution.

What were the Court’s Observations?

• The power of the High Court under Article 227 is supervisory in nature and is exercised to ensure courts and tribunals under its supervision act within the limits of their jurisdiction conferred by law. 
• This supervisory power is to be sparingly exercised in cases where errors are apparent on the face of record, occasioning grave injustice by the court or tribunal either assuming jurisdiction which it does not have, failing to exercise jurisdiction which it does have, or exercising its jurisdiction in a perverse manner. 
• The essence of power under Article 227 being supervisory, it cannot be invoked to usurp the original jurisdiction of the court which it seeks to supervise. 
• It cannot be invoked to supplant a statutory legal remedy available under the Civil Procedure Code, 1908. 
• The existence of an appellate remedy under Section 96 of the Code operates as a near total bar to exercise of supervisory jurisdiction under Article 227. 
• The Civil Procedure Code is a self-contained Code, with Order VII Rule 11 enumerating specific circumstances in which a trial court may reject a plaint. 
• Rejection of a plaint amounts to a deemed decree which is appealable before the High Court under Section 96 of the Code. 
• The High Court, by rejecting the plaint on the ground it was barred by law, not only substituted itself as the court of first instance but also rendered nugatory a valuable right of appeal available to the appellant. 
• The Court distinguished its earlier judgment in Frost (International) Ltd. v. Milan Developers, noting that observations therein were not relevant as the High Court in the present case had not exercised supervisory power to correct a jurisdictional error but had usurped original jurisdiction. 
• Procedural law provides the necessary legal infrastructure upon which the edifice of rule of law is built, and short-circuiting of procedure to reach hasty outcomes subverts certainty and consistency in law. 
• No offence under criminal law was involved in this case, as it was purely a civil dispute regarding property rights and jurisdictional matters.

What is the Scope and Limitation of the High Court’s Supervisory Jurisdiction Under Article 227 in Relation to Rejection of Plaints? 

• Article 227 of the COI establishes the High Court's power of superintendence over all subordinate courts and tribunals within its territorial jurisdiction.  
• This supervisory power is an important constitutional safeguard that ensures judicial accountability and maintains standards across the judicial hierarchy. 
• The High Court's superintendence powers under Article 227 include: 
  • Overseeing all courts and tribunals in its jurisdiction. 
  • Calling for returns from subordinate courts. 
  • Making rules and prescribing forms to regulate court practices. 
  • Prescribing forms for record-keeping by court officers. 
  • Setting fee tables for court officers and legal practitioners. 
  • These powers come with limitations, including: 
    • Any rules made must not conflict with existing laws. 
    • The governor's approval is required for rules, forms, and fee tables. 
    • The High Court has no superintendence over military tribunals. 
• Regarding Order VII Rule 11 of the Civil Procedure Code, it provides grounds for rejection of plaints, including: 
  • Failure to disclose a cause of action. 
  • Undervaluation of relief with failure to correct within time. 
  • Insufficient court fee stamps with failure to correct within time. 
  • When the suit appears barred by law. 
  • Non-filing of duplicate plaint. 
  • Non-compliance with Rule 9 provisions. 
• The Supreme Court in K. Akbar Ali v. Umar Khan (2021) has clarified that these grounds are not exhaustive, and courts may reject plaints on other appropriate grounds as well. 
• The power of plaint rejection is a preliminary screening mechanism that helps courts filter out legally untenable cases at the threshold, while the High Court's supervisory jurisdiction under Article 227 serves as a constitutional safeguard to ensure proper administration of justice throughout the judicial system.