NCLT jurisdiction bars civil suits where oppression and mismanagement relief can cover access to company records and injunctions.

Civil court jurisdiction is excluded by Section 430 of the Companies Act, 2013 where the relief sought can be granted by the National Company Law Tribunal in oppression and mismanagement proceedings. Sections 241 and 242 give the Tribunal wide powers to pass interim and final orders, regulate company affairs, remove directors, order recovery of undue gains, and grant other just and equitable relief. The Tribunal's flexible procedure under Section 424 and Rule 11 of the NCLT Rules, 2016 supports effective relief, and the civil suit seeking restraint on access to company accounts and files was therefore within the Tribunal's competence. The injunction application ought to be pursued before the Tribunal.

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Issues: Whether the civil court had jurisdiction to entertain a suit and injunction application seeking restraint against access to company accounts and files, where parallel proceedings alleging oppression and mismanagement were pending before the National Company Law Tribunal.

Analysis: Section 430 of the Companies Act, 2013 bars civil court jurisdiction in respect of matters which the Tribunal is empowered to determine. Sections 241 and 242 confer wide powers on the Tribunal in oppression and mismanagement proceedings, including interim orders, regulation of company affairs, removal of directors, recovery of undue gains, and any other just and equitable relief. Section 424 and Rule 11 of the National Company Law Tribunal Rules, 2016 further support the Tribunal's power to adopt flexible procedure and grant effective relief, while Section 280 indicates the breadth of its jurisdiction. The relief sought in the suit was held to be capable of being granted by the Tribunal and was not outside its competence merely because it was framed as an injunction against illegal access, alteration, or tampering of company records.

Conclusion: The civil court's jurisdiction was barred, and the injunction relief ought to be pursued before the Tribunal; the order of the trial court dismissing the injunction application was restored.

Ratio Decidendi: Where the relief sought in a civil suit is one that can be granted by the National Company Law Tribunal in proceedings for oppression and mismanagement, the civil court's jurisdiction is excluded by Section 430 of the Companies Act, 2013.

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