Civil court bar in company management disputes where the Companies Act provides a specific remedy for director removal.

Disputes concerning a company's internal management, including removal of a director, are governed by the specific statutory mechanism under the Companies Act, 1956, particularly the remedy under Section 284. Where that statutory procedure exists, civil court jurisdiction is barred under Section 9 CPC, and a suit for injunction cannot be used to bypass the Companies Act framework. The text also notes that interim relief was unwarranted because no prima facie case, balance of convenience, or irreparable injury was shown.

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Issues: Whether a civil suit for injunction was maintainable to restrain company directors from dealing with the internal management of the company, including removal of a director, in view of the remedy provided under the Companies Act, 1956 and the bar under Section 9 of the Code of Civil Procedure, 1908.

Analysis: The dispute related to internal management of the company and the grievance concerning removal of a director was governed by the statutory mechanism under Section 284 of the Companies Act, 1956. The availability of that specific procedure, together with the principle that civil courts cannot entertain suits where cognizance is expressly or impliedly barred, meant that the petitioner could not bypass the statutory remedy by filing a suit for injunction. The Court also upheld the concurrent view that no prima facie case, balance of convenience, or irreparable injury was established for grant of interim relief.

Conclusion: The civil suit was not maintainable and the revision petition failed.

Ratio Decidendi: Where the Companies Act, 1956 provides a specific mechanism for resolution of disputes concerning removal of directors and internal company management, civil court jurisdiction is barred and an injunction suit cannot be used to circumvent the statutory remedy.

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