Section 430 jurisdiction bar applies where share transfer rectification and connected reliefs fall within the Tribunal's competence.

Section 430 of the Companies Act, 2013 bars civil court jurisdiction where the core dispute concerns refusal to register transfer of shares, rectification of the register of members, and connected reliefs within the Tribunal's competence under sections 58 and 59 read with Rule 70 of the NCLT Rules, 2016. The Calcutta High Court reasoned that once the statutory forum can decide whether applicants are entitled to be treated as members, the civil court cannot entertain overlapping claims. It also noted that interim, consequential, oppression and mismanagement reliefs should be pursued before the Tribunal to avoid conflicting findings on the same underlying controversy.

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Issues: (i) whether the civil suit was barred by section 430 of the Companies Act, 2013 in view of the remedies available before the National Company Law Tribunal for refusal to register transfer of shares and rectification of the register; (ii) whether the civil court could grant interim and consequential reliefs relating to alleged oppression, mismanagement, and corporate control when a proceeding on the same core controversy was already pending before the Tribunal.

Issue (i): whether the civil suit was barred by section 430 of the Companies Act, 2013 in view of the remedies available before the National Company Law Tribunal for refusal to register transfer of shares and rectification of the register.

Analysis: The dispute pleaded in the suit centred on refusal to register transfer of shares, rectification of the register of members, and the consequences flowing from such refusal. Those matters were held to fall within the statutory competence of the Tribunal under sections 58 and 59 of the Companies Act, 2013, read with Rule 70 of the National Company Law Tribunal Rules, 2016. The Court held that once the statutory forum is empowered to determine the very issue raised, the bar under section 430 operates and the civil court cannot entertain the suit. The reasoning also proceeded on the principle that the proper forum must decide whether the applicants are entitled to be treated as members and, only thereafter, whether further reliefs under the oppression and mismanagement provisions can arise.

Conclusion: The suit was held to be barred to that extent, and the civil court lacked jurisdiction to entertain the controversy.

Issue (ii): whether the civil court could grant interim and consequential reliefs relating to alleged oppression, mismanagement, and corporate control when a proceeding on the same core controversy was already pending before the Tribunal.

Analysis: The Court found that the reliefs sought in the suit substantially overlapped with those sought before the Tribunal, and that the alleged beneficial interest, trustee relationship, and corporate control issues all depended on the antecedent question of registration of shares. It held that the Tribunal could grant interim orders, injunctions, and consequential directions under Rule 70, and that entertaining the suit would create the risk of conflicting findings on the same underlying facts. The Court further held that the appellants could pursue any consequential oppression and mismanagement reliefs before the Tribunal after obtaining a finding in their favour on rectification.

Conclusion: The civil court was held not to be the proper forum for interim or consequential reliefs, and no injunction was granted.

Final Conclusion: The appeal failed because the dispute was held to be triable by the Tribunal under the Companies Act, 2013, leaving the civil court without jurisdiction to proceed.

Ratio Decidendi: Where the statutory tribunal is expressly empowered to decide the core dispute, including rectification of the register of members and connected interim reliefs, section 430 of the Companies Act, 2013 excludes civil court jurisdiction over the same controversy.

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