Civil court jurisdiction barred in company property dispute where plaint disclosed matters reserved for the Tribunal under the Companies Act.

A civil suit seeking declaratory and injunctive relief over company property was held barred because the plaint itself showed a dispute concerning company affairs, including division of assets, sale proceeds, liabilities, and allocation of properties under alleged director meeting minutes. Since the Companies Act, 2013 vests the Tribunal with jurisdiction over matters such as oppression and mismanagement and related company disputes, Section 430 excluded civil court jurisdiction on the pleaded facts. As the bar was apparent from the plaint, the suit was correctly rejected under Order VII Rule 11(d) CPC.

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Issues: Whether the civil suit seeking declaratory and injunctive relief in relation to company property was barred by Section 430 of the Companies Act, 2013 and liable to rejection under Order VII Rule 11(d) of the Code of Civil Procedure, 1908.

Analysis: The suit was founded on alleged minutes of a meeting between directors dealing with division of company assets, sale proceeds, liabilities, and allocation of properties. The dispute, as disclosed in the plaint, concerned the affairs of the company and rights arising out of arrangements touching company property. The Act, 2013 confers jurisdiction on the Tribunal in matters such as oppression and mismanagement, compromise or arrangement, and related company disputes, and Section 430 excludes civil court jurisdiction where the Tribunal or Appellate Tribunal is empowered to determine the matter. On the pleadings, the controversy was not a simple civil dispute detached from the statutory company regime, but one falling within the field assigned to the Tribunal.

Conclusion: The civil suit was barred by Section 430 of the Companies Act, 2013 and was correctly rejected under Order VII Rule 11(d) of the Code of Civil Procedure, 1908.

Ratio Decidendi: Where the relief claimed in a civil suit is in substance referable to matters that the Companies Act, 2013 empowers the Tribunal to determine, civil court jurisdiction is excluded and the plaint is liable to rejection if the bar is apparent from the plaint itself.

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