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Issues: Whether the civil court had jurisdiction to entertain the suit in view of the availability of remedies before the National Company Law Tribunal for grievances alleging oppression and mismanagement and for reliefs concerning the company's affairs and property.
Analysis: The plaint disclosed allegations that the company's affairs were being conducted in a manner prejudicial to the plaintiff and the company, and the reliefs sought included setting aside a sale deed, restraining further alienation of company property, and directing deposit of sale consideration. Sections 241, 242 and 244 of the Companies Act, 2013 provided a statutory remedy before the Tribunal for a member satisfying the shareholding threshold. The Tribunal's powers under Section 242 were wide enough to regulate future conduct of the company, set aside agreements or acts relating to company property, grant interim orders, and pass residuary orders under clause (m). In view of Section 430, once the Tribunal was empowered to determine the matter, the jurisdiction of the civil court stood excluded.
Conclusion: The civil suit was not maintainable and the civil court lacked jurisdiction to entertain it.