MITC Rolling Mills Private Limited & Anr. v. M/s Renuka Realtors & Ors., 2025
An order rejecting the plaint amounts to a decree and therefore falls within the main provision of Section 13(1A).
Judgement Details
Court
Supreme Court of India
Date of Decision
14 November 2025
Judges
Justice Vikram Nath and Justice Sandeep Mehta
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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The appellant filed a commercial suit for recovery of over ₹2.5 crore.
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The respondent-defendant filed an application under Order VII Rule 11 CPC to reject the plaint, claiming Pre-Institution Mediation was not conducted.
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The Trial Court allowed the application and rejected the plaint.
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The appellant appealed to the Bombay High Court under Section 13(1A) CCA, which dismissed the appeal as non-maintainable, reasoning that an order rejecting a plaint was not listed in Order XLIII CPC.
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Aggrieved, the appellant moved the Supreme Court.
Issues
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Whether an order allowing rejection of a plaint under Order VII Rule 11 amounts to a decree and is appealable under Section 13(1A) CCA?
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Whether an order rejecting the application to reject a plaint is appealable under Section 13(1A)?
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Distinguishing the present case from Bank of India v. Maruti Civil Works, 2023, where only an interlocutory order was involved?
Held
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Order allowing rejection of plaint = decree = appealable under Section 13(1A) CCA.
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Order rejecting application to reject plaint is interlocutory and are not appealable under Section 13(1A), can be challenged under revision/Article 227.
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Section 13(1A) CCA must be read harmoniously; proviso to Section 13(1A) cannot restrict main provision.
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Appeal by the appellant maintainable, restored to original High Court file/number.
Analysis
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It Clarifies appealability of orders under Commercial Courts Act.
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It Distinguishes final vs interlocutory orders for appeal purposes.
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It Reinforces that procedural provisions must be interpreted harmoniously, not in a restrictive manner.
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It Confirms High Court can entertain revision or Article 227 petition when an order is interlocutory.
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It Restores litigant’s right to challenge final orders rejecting plaints, strengthening procedural clarity in commercial suits.