Res judicata and civil court bar under the Companies Act justified rejection of a plaint over an already adjudicated share dispute.

A plaint was held liable to rejection where it disclosed a prior merits-based adjudication on the same family arrangement and share dispute, and where the reliefs substantially fell within the Companies Act, 2013 framework governed by the Tribunal's jurisdiction. Sections 241 and 242 placed the controversy before the statutory forum, while Section 430 barred civil court entertainment of such matters. The prior decision also triggered res judicata and issue estoppel because the relevant issues had already been determined in substance. The court rejected the argument that only part of the plaint could be struck out, holding that the suit as framed was barred in its entirety and had to fail under Order VII Rule 11(d) CPC.

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Issues: Whether the plaint was liable to be rejected as barred by law on the grounds of res judicata, issue estoppel and the statutory bar of civil court jurisdiction under the Companies Act, 2013.

Analysis: The plaint itself referred to an earlier company law adjudication concerning the same family arrangement and the same subject matter of shares. The earlier proceeding had been decided on merits under the oppression and mismanagement provisions corresponding to the present statutory regime, and the plaintiffs had also acknowledged a pending challenge to that decision. On a plain and meaningful reading of the plaint and the documents referred to in it, the controversy raised in the suit substantially fell within the jurisdiction of the Tribunal under Sections 241 and 242 of the Companies Act, 2013, while Section 430 barred the civil court from entertaining such matters. Since the prior adjudication had already determined the relevant issues in substance, the doctrines of res judicata and issue estoppel were attracted. The plea that only part of the plaint could be rejected did not survive because the suit as framed was barred in its entirety.

Conclusion: The plaint was barred by law and was liable to be rejected; the civil revision succeeded and the plaint was rejected.

Final Conclusion: The suit could not be maintained before the civil court, as the dispute had already been adjudicated in substance and the proper forum lay elsewhere under the Companies Act regime.

Ratio Decidendi: Where the plaint itself discloses a prior merits-based adjudication on the same underlying issue and the reliefs claimed fall within a forum whose jurisdiction is expressly coupled with a statutory civil court bar, the plaint is rejected under Order VII Rule 11(d) of the Code of Civil Procedure.

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