Civil court jurisdiction barred over company dispute where challenge to board resolution and sale deed lay before the NCLT.

Civil court jurisdiction was barred where the suit substantially challenged a board resolution and the consequential sale deed, both arising from the same corporate dispute pending before the NCLT under the Companies Act, 2013. Section 430 excluded civil court scrutiny because the Tribunal was empowered to determine the underlying matters concerning management and company property. The challenge to the sale deed depended on the validity of the board resolution, and the statutory remedy before the NCLT was an efficacious forum. The objection under Order VII Rule 11 / section 9A principles was therefore correctly upheld.

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Issues: Whether the civil court's jurisdiction was barred in a suit challenging a board resolution and sale deed when a company petition under sections 241 and 242 of the Companies Act, 2013 was pending before the NCLT.

Analysis: The reliefs in the civil suit substantially assailed the board resolution of 2 February 2014 and the consequential sale deed of 30 June 2014. The challenge before the NCLT also arose out of the same corporate dispute and sought reliefs in relation to the management of the company and the company property. Section 430 of the Companies Act, 2013 expressly excludes the civil court's jurisdiction in respect of matters which the Tribunal or Appellate Tribunal is empowered to determine. The Court held that the attack on the sale deed was essentially dependent on the challenge to the board resolution, which fell within the NCLT's domain. The contention based on section 242(2)(g) of the Companies Act, 2013 did not assist the petitioner at this stage, and the pendency of the company petition showed that an efficacious statutory forum was already available.

Conclusion: The civil court's jurisdiction was barred, and the objection under section 9A of the Code of Civil Procedure, 1908 was rightly upheld.

Final Conclusion: The writ petition failed, and the order dismissing the challenge to the jurisdictional ruling was sustained.

Ratio Decidendi: Where the substance of the civil suit concerns matters that are within the Tribunal's power under the Companies Act, 2013, section 430 bars the civil court from entertaining the suit even if the reliefs are framed as challenges to corporate acts and consequential transactions.

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