Suit Alleging Coercion Not Rejectable Under Order VII Rule 11 CPC

Source: Supreme Court 

Why in News?

The bench of Justices Sanjay Kumar and K Vinod Chandran in the case of J. Muthurajan & Anr. v. S. Vaikundarajan & Ors. (2026) held that a civil suit alleging coercion, undue influence, or misrepresentation cannot be rejected at the threshold under Order VII Rule 11 of the Code of Civil Procedure, 1908 (CPC).  The Court set aside the concurrent findings of the Trial Court and the Madras High Court, which had dismissed the Appellant's suit as an abuse of process of law.

What was the Background of J. Muthurajan & Anr. v. S. Vaikundarajan & Ors. (2026) Case? 

• The dispute arose from a 308-page partition deed (KBPP) which all parties admitted to having signed. 
• The Respondent-Vaikundarajan Group sought to enforce the deed as a binding settlement, while the Appellant-Jegatheesan Group claimed the deed was executed under coercion, undue influence, and misrepresentation, and was only a "tentative draft." 
• A Conciliation Award dated January 2, 2019, purportedly issued under the Arbitration and Conciliation Act, 1996, further complicated the matter. The Award was signed by a half-brother acting as conciliator, certifying the KBPP as a formally concluded settlement. 
• The Respondent argued that together the documents constituted an enforceable conciliation award under Section 36 of the Arbitration and Conciliation Act, 1996. 
• The Appellant alleged that no real conciliation occurred and that the Award was fabricated to legitimise an inequitable arrangement. 
• The Trial Court rejected the Appellant's plaint under Order VII Rule 11 CPC, treating it as vexatious and an abuse of process of law, purely because the suit contained grounds of coercion, undue influence, and misrepresentation. 
• The Madras High Court upheld the Trial Court's decision, leading to the present appeal before the Supreme Court.

What were the Court's Observations? 

• The Court, in a judgment authored by Justice K Vinod Chandran, observed that the Trial Court and the High Court committed a fundamental error in dismissing the suit at the pleading stage itself. 
• The Court held that since the Appellants had raised triable issues regarding the correctness of the partition deed as well as the conciliation award, the plaint could not be peremptorily rejected at the threshold. 
• The Court further noted: "We hence find the order of the Trial Court as confirmed by the High Court, resulting in the rejection of the plaint to be egregiously erroneous in law. We are of the opinion that there is a prima facie cause of action disclosed etc. in the suit and it cannot be termed vexatious or an abuse of the process of law." 
• The Court emphasized that the cause of action as disclosed was real and not illusory or fictional, and that the factual averments, legal grounds, and relief sought were not meaningless nor could it be said at that stage that the suit was bound to fail. 
• The Supreme Court accordingly set aside the impugned rulings of both the Trial Court and the Madras High Court. 

What is Order VII Rule 11 CPC - Rejection of Plaint? 

• Order VII Rule 11 of the Code of Civil Procedure, 1908 provides for rejection of plaint in specific circumstances enumerated thereunder. 
  • Clause (a) mandates rejection of plaint where it does not disclose a cause of action. 
  • Clause (b) provides for rejection where the relief claimed is undervalued and the plaintiff fails to correct the valuation within the time fixed by the Court. 
  • Clause (c) deals with cases where the relief is properly valued but the plaint is insufficiently stamped, and the plaintiff fails to supply requisite stamp-paper within the time fixed. 
  • Clause (d) mandates rejection where the suit appears from the statement in the plaint to be barred by any law. 
  • Clause (e) provides for rejection where the plaint is not filed in duplicate. 
  • Clause (f) stipulates rejection where the plaintiff fails to comply with the provisions of Rule 9 of Order VII. 
• The proviso stipulates that time for correction of valuation or supplying stamp-paper shall not be extended unless the Court is satisfied that the plaintiff was prevented by exceptional cause and refusal would cause grave injustice. 
• The power to reject a plaint under Order VII Rule 11 is an extraordinary power and must be exercised with great caution and circumspection. 
• Under clause (d), the Court must determine from the averments in the plaint itself whether the suit is barred by any law, including the law of limitation. 
• The scope of enquiry under Order VII Rule 11(d) is limited to the face of the plaint and the documents annexed thereto or referred to therein. 
• The defence set up by the defendant cannot be considered while deciding an application under Order VII Rule 11 CPC. 
• The power should be exercised only in clear and manifest cases where the plaint is ex facie barred. 
• Where determination of limitation requires examination of evidence or consideration of mixed questions of law and fact, the plaint cannot be rejected under clause (d). 
• The Court cannot travel beyond the four corners of the plaint while considering an application for rejection under Order VII Rule 11. 
• Where several reliefs are claimed and even one relief is within limitation, the plaint cannot be rejected in its entirety as barred by law. 
• The provision should not be used to shut out genuine claims merely on technical grounds without full adjudication on merits.