Declaratory suit valuation and civil jurisdiction: plaint valuation governs, and Section 430 bar applies only to oppression claims.

A declaratory suit with consequential injunction was valued by the plaintiffs under Section 7(iv)(c) of the Court Fees Act, and that valuation also governed jurisdiction under Section 8 of the Suits Valuation Act. The challenge that the plaint was undervalued failed because the dispute concerned the legality of membership-termination proceedings, not a monetary liability fixed by the club's internal rules. The text also explains that Section 430 of the Companies Act does not bar a civil suit unless the substance of the claim falls within the oppression and mismanagement remedy under Section 241. On that reasoning, the civil court retained jurisdiction.

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Issues: (i) Whether the plaint was liable to be rejected under Order VII Rule 11(b) of the Code of Civil Procedure, 1908 on the ground that the relief was undervalued. (ii) Whether the suit was barred by Section 430 of the Companies Act, 2013 on the premise that the plaintiffs' grievance lay only before the National Company Law Tribunal.

Issue (i): Whether the plaint was liable to be rejected under Order VII Rule 11(b) of the Code of Civil Procedure, 1908 on the ground that the relief was undervalued.

Analysis: The suit sought declaration and permanent injunction. In such a suit, Section 7(iv)(c) of the Court Fees Act, 1870 permits the plaintiff to value the relief sought in the plaint, and Section 8 of the Suits Valuation Act, 1887 makes the jurisdictional value the same as the court-fee valuation. The plaint was valued at Rs. 2 crores and appropriate court fee was paid. The challenge based on the members' alleged liability limit of Rs. 100/- was rejected because the suit was not about financial liability to the club but about the legality of proceedings initiated for termination of membership, and the valuation for such declaratory relief lay within the plaintiffs' discretion.

Conclusion: The plaint was not undervalued and no ground for rejection under Order VII Rule 11(b) was made out.

Issue (ii): Whether the suit was barred by Section 430 of the Companies Act, 2013 on the premise that the plaintiffs' grievance lay only before the National Company Law Tribunal.

Analysis: Section 241 of the Companies Act, 2013 provides a remedy before the National Company Law Tribunal for oppression and mismanagement. However, the present suit did not seek redress for oppression or mismanagement; its subject matter was the legality of the show cause notices issued to the plaintiffs proposing termination of membership. The grievance was therefore not one falling within the exclusive statutory forum under Section 241, and the bar under Section 430 did not apply. The court also treated the reliance on the rectification provision under the earlier Companies Act as inapposite because no removal from the register had yet occurred.

Conclusion: The civil court's jurisdiction was not barred and the plaint could not be rejected on that ground.

Final Conclusion: The application for rejection of the plaint failed on both grounds and was dismissed, leaving the suit to proceed on merits.

Ratio Decidendi: In a suit for declaration with consequential relief, the plaintiff's valuation under Section 7(iv)(c) of the Court Fees Act, 1870 will ordinarily govern jurisdiction under Section 8 of the Suits Valuation Act, 1887, and the civil court's jurisdiction is not ousted by Section 430 of the Companies Act, 2013 unless the suit in substance seeks relief for oppression and mismanagement within the statutory scheme of Section 241.

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