Pleading and statutory bar principles: a plaint lacking material facts, or seeking to obstruct exclusive recovery proceedings, may be rejected at threshold.

A plaint must plead all material facts constituting a complete cause of action, including when the right to sue arose and the particulars of any alleged fraud or misrepresentation; bare assertions are insufficient, and the plaint is liable to rejection under Order VII Rule 11(a) if those essentials are missing. A civil suit is also barred under Order VII Rule 11(d) where the dispute falls within the exclusive recovery jurisdiction of the Debts Recovery Tribunal and the requested injunctions are hit by the Specific Relief Act restrictions, including Sections 41(b) and 41(h). The result is rejection of the plaint at the threshold.

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Issues: (i) Whether the plaint disclosed a complete cause of action and satisfied the pleading requirements under Order VII Rule 1 and Order VI Rule 2 of the Code of Civil Procedure, 1908 so as to survive an application under Order VII Rule 11(a); (ii) Whether the suit was barred by law, including the jurisdictional bar under the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 and the restrictive provisions of the Specific Relief Act, 1963, so as to attract Order VII Rule 11(d).

Issue (i): Whether the plaint disclosed a complete cause of action and satisfied the pleading requirements under Order VII Rule 1 and Order VI Rule 2 of the Code of Civil Procedure, 1908 so as to survive an application under Order VII Rule 11(a)

Analysis: The plaint was required to state the material facts constituting the cause of action and the time when it arose. Read as a whole, it did not clearly set out when the agreements allegedly became illegal, when the alleged right to sue accrued, or the material particulars of the alleged fraud and misrepresentation. Mere assertions were not enough where fraud and undue influence were pleaded. The absence of essential facts meant that the plaint did not disclose a complete cause of action.

Conclusion: The plaint failed on the ground of non-disclosure of cause of action and was liable to be rejected under Order VII Rule 11(a) in favour of the appellant.

Issue (ii): Whether the suit was barred by law, including the jurisdictional bar under the Recovery of Debts Due to Banks and Financial Institutions Act, 1993 and the restrictive provisions of the Specific Relief Act, 1963, so as to attract Order VII Rule 11(d)

Analysis: The disputes in the suit overlapped with the bank's recovery proceedings before the Debts Recovery Tribunal, whose jurisdiction over such matters is exclusive under Sections 17 and 18 of the Recovery of Debts Due to Banks and Financial Institutions Act, 1993. A civil suit seeking to stall those proceedings and to obtain relief on the same subject matter was not maintainable. The prayers for injunction were also hit by Section 41(b) and Section 41(h) of the Specific Relief Act, 1963. The Court treated the suit as a vexatious attempt to obstruct recovery proceedings and held that clever drafting could not create a valid cause of action.

Conclusion: The suit was barred by law and the plaint was liable to be rejected under Order VII Rule 11(d) in favour of the appellant.

Final Conclusion: The revision succeeded, the impugned order was set aside, and the plaint was rejected at the threshold.

Ratio Decidendi: A plaint must disclose all material facts constituting a complete cause of action, and where the suit is barred by an exclusive statutory recovery forum and allied injunction restrictions, it is liable to rejection under Order VII Rule 11(a) and 11(d) of the Code of Civil Procedure, 1908.

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