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Issues: Whether the High Court, in exercise of supervisory jurisdiction under Article 227 of the Constitution of India, could reject a plaint when the Civil Procedure Code, 1908 provides a specific mechanism under Order VII Rule 11 and a consequential appeal under Section 96.
Analysis: The supervisory power under Article 227 is meant to keep subordinate courts within jurisdictional bounds and cannot be used to assume original jurisdiction or bypass the statutory scheme of the Civil Procedure Code, 1908. Rejection of a plaint is specifically regulated by Order VII Rule 11 and such rejection operates as a deemed decree, attracting an appeal under Section 96. If the High Court itself rejects the plaint in supervisory jurisdiction, it displaces the trial court's original function and deprives the litigant of the appellate remedy that would otherwise follow. The principle was applied to hold that the High Court could not short-circuit the procedure by directly entertaining a prayer for rejection of plaint under Article 227.
Conclusion: The High Court lacked jurisdiction to reject the plaint in exercise of Article 227 supervisory powers, and the impugned order was unsustainable.