Supreme Court of India has clarified that a High Court cannot reject a plaint while exercising its supervisory jurisdiction under Article 227 of the Constitution. The judgment, delivered in the case of K. Valarmathi & Ors. vs. Kumaresan (Civil Appeal No. ___ of 2025, arising out of SLP (C) No. 21466/2024), reinforces the supervisory limits of Article 227 and underscores the procedural framework of the Code of Civil Procedure (CPC), 1908.
Case Background
The case originated from a challenge to a Madras High Court decision that rejected a plaint, citing it as barred by the Prohibition of Benami Property Transactions Act, 1988. The dispute involved agricultural land purchased by one Kathiresan in the name of his nephew, Kumaresan, allegedly on astrological advice. After Kathiresan’s demise, his wife and daughters (the appellants) claimed possession of the land, leading to disputes when Kumaresan attempted to sell it. The appellants filed a civil suit, which the Madras High Court dismissed under its Article 227 jurisdiction.
Supreme Court’s Ruling
A bench comprising Justice PS Narasimha and Justice Joymalya Bagchi set aside the Madras High Court’s judgment, emphasizing that the supervisory power under Article 227 is meant to ensure that subordinate courts and tribunals operate within their jurisdictional limits, not to usurp the original jurisdiction of trial courts. The Court observed:
“The power under Article 227 is supervisory and is exercised to ensure courts and tribunals under its supervision act within the limits of their jurisdiction conferred by law. This power is to be sparingly exercised in cases where errors are apparent on the face of the record, occasioning grave injustice.”
The Court further clarified that the CPC provides a structured mechanism for rejecting a plaint under Order VII Rule 11, which lists specific grounds for such rejection, including when a suit appears to be barred by law. A trial court’s decision to reject a plaint is deemed a decree under the CPC and is appealable under Section 96. Allowing a High Court to reject a plaint under Article 227 would bypass this statutory scheme and deprive litigants of their right to appeal.
The Supreme Court also distinguished its 2022 ruling in Frost (International) Ltd. v. Milan Developers, noting that in that case, the High Court exercised revisional powers, not supervisory jurisdiction under Article 227. The Court reaffirmed its 2014 decision in Jacky v. Tiny @ Antony & Ors., which held that a plaint cannot be rejected under Articles 226 or 227.
Supervisory vs. Original Jurisdiction: Article 227 does not permit a High Court to assume the role of a trial court or interfere with its original jurisdiction.
The CPC’s framework, including Order VII Rule 11 and appeal provisions, cannot be overridden by invoking Article 227.Judicial Restraint: The supervisory power under Article 227 must be exercised sparingly, only to correct jurisdictional errors or prevent grave injustice
This ruling strengthens the procedural integrity of civil litigation in India by ensuring that trial courts retain primary authority to adjudicate plaints. It also protects litigants’ rights to statutory remedies, such as appeals, and curbs the misuse of supervisory jurisdiction to prematurely dismiss suits. Legal practitioners and litigants must now ensure that challenges to plaints are raised before trial courts under the CPC, rather than directly approaching High Courts under Article 227.
Case Details
Cause Title: K. Valarmathi & Ors. vs. Kumaresan (2025 INSC 606)
Counsel for Appellants: Advocate M. Gireesh Kumar, AOR Ankur S. Kulkarni, Advocates A.S. Naushad, Puspita Basak, TarunCounsel
For Respondent: Senior Advocate R. Baskaran, AOR Aswathi M.K., Advocates Arivazhagan, S. Raju, V.C. Venkatachalam
Amicus Curiae: Senior Advocate V. Prabhakar
