Company court jurisdiction is limited to matters assigned by statute; share forfeiture disputes may proceed in civil court.

Section 10 of the Companies Act, 1956 confers jurisdiction on the company court only for matters specifically assigned by the Act and does not create a general jurisdiction over all company-related disputes. A challenge to forfeiture of shares under a company's articles was therefore outside the company court's maintainable jurisdiction. In the absence of an express statutory remedy and where civil jurisdiction is not excluded by necessary implication, the ordinary civil court remedy under section 9 of the Code of Civil Procedure, 1908 remains available. Earlier decisions limiting section 10 to specified matters were followed, and authorities based on inapplicable or deleted provisions were distinguished.

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Issues: Whether an application challenging forfeiture of shares under the company's articles was maintainable before the company court, and whether section 10 of the Companies Act, 1956 conferred general jurisdiction on the High Court to entertain such a dispute.

Analysis: The scheme of sections 2(11) and 10 of the Companies Act, 1956 shows that the expression "court" denotes the court having jurisdiction under the Act in respect of the particular matter, and section 10 does not create a blanket jurisdiction in the High Court over every dispute connected with a company. The Act confers jurisdiction on the court only in specified matters, while other powers are vested in different authorities such as the Central Government and the Company Law Board. Forfeiture of shares under the articles is not one of the matters for which the Act expressly provides a remedy before the company court. In the absence of an express statutory provision, and where jurisdiction of the civil court is not excluded by necessary implication, the ordinary remedy remains available under section 9 of the Code of Civil Procedure, 1908. Earlier decisions holding that section 10 does not confer exclusive jurisdiction over all company matters were followed, while authorities based on now-deleted or inapplicable provisions were distinguished.

Conclusion: The application was not maintainable before the company court, and the challenge to forfeiture of shares could not be entertained under section 10 of the Companies Act, 1956.

Ratio Decidendi: Section 10 of the Companies Act, 1956 confers jurisdiction on the company court only in respect of matters specifically assigned by the Act and does not oust the ordinary civil jurisdiction for disputes not expressly provided for by the statute.

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