Sunday, 22 October 2017

Whether plaint can be rejected if single material fact is omitted?

In the light of the afore-stated legal position,
let us examine the averments made in the plaint
so as to find out whether the plaint discloses
the cause of action, and whether the suit is
barred under any law as contemplated in Clause
(a) and Clause (d) respectively of Rule 11 of
Order VII. At this juncture, it would be also

apposite to mention that Order VI Rule 2 requires
that every pleadings shall contain, and contain
only a statement in concise form and of material
facts on which the party pleading relies for his
claim or defence as the case may be, but not the
evidence by which they are to be proved. Thus,
though the pleadings must contain a statement in
concise form of material facts, it need not
contain the evidence by which they are to be
proved. At this juncture, it would be also
relevant to mention that Order VII Rule 1 states
as to what particulars should be contained in the
plaint, and as per Clause (e) of the said Rule,
the plaint must contain the facts constituting
the cause of action, and when it arose. As per
Clause (f) thereof, the plaint also must contain
the facts showing that the Court has
jurisdiction. The distinction between “material
facts” and “particulars” has been succinctly
described by the Supreme Court in case of Sopan
Sukhdeo Sable and Ors. Vs. Assistant Charity
Commissioner and Ors. (supra). Paragraph 20
thereof reads as under:-
“20. There   is   distinction   between   ’material
facts’   and   ’particulars’.   The   words   ’material
facts’ show that the facts necessary to formulate
a   complete   cause   of   action   must   be  stated.
Omission   of   a  single   material   fact   leads   to  an
incomplete cause of action and the statement or
plaint   becomes   bad.   The   distinction   which   has
been   made   between   ’material   facts’   and
’particulars’ was brought by Scott, L.J. in Bruce
v.   Odhams   Press   Ltd.   (1936)   1   KB   697   in   the
following passage :

The cardinal provision in Rule 4 is that the
statement   of   claim   must   state   the   material
facts.   The   word   "material"   means   necessary
for   the   purpose   of   formulating   a   complete
cause of action; and if any one "material"
statement is omitted, the statement of claim
is   bad;   it   is   "demurrable"   in   the   old
phraseology, and in the new is liable to be
"struck out" under R.S.C. Order XXV, Rule 4
(see   Philipps   v.   Philipps   ((1878)   4   QBD
127)); or "a further and better statement of
claim" may be ordered under Rule 7. 
The   function   of   "particulars"   under   Rule   6
is quite different. They are not to be used
in   order   to   fill   material   gaps   in   a
demurrable   statement   of   claim   ­   gaps   which
ought   to   have   been   filled   by   appropriate
statements   of   the   various   material   facts
which   together   constitute   the   plaintiff’s
cause of action. The use of particulars is
intended   to   meet   a   further   and   quite
separate requirement of pleading, imposed in
fairness and justice to the defendant. Their
function   is   to   fill   in   the   picture   of   the
plaintiff’s cause of action with information
sufficiently   detailed   to   put   the   defendant
on his guard as to the case he had to meet
and to enable him to prepare for trial. 
The dictum of Scott, L.J. in Bruce case (supra)
has  been quoted  with approval by this  Court  in
Samant   N.   Balkrishna   v.   George   Fernandez   (1969
(3)   SCC   238),   and   the   distinction   between
"material   facts"   and   "particulars"   was   brought
out in the following terms:
The   word   ’material’   shows   that   the   facts
necessary   to   formulate   a   complete   cause   of
action must be stated. Omission of a single
material   fact   leads   to   an   incomplete   cause
of action and the statement of claim becomes
bad.   The   function   of   particulars   is   to
present   as   full   a   picture   of   the   cause   of
action   with   such   further   information   in
detail   as   to   make   the   opposite   party

understand the case he will have to meet.
Rule   11   of   Order   VII   lays   down   an   independent
remedy   made   available   to   the   defendant   to
challenge the maintainability of the suit itself,
irrespective of his right to contest the same on
merits. The law ostensibly does not contemplate
at any stage when the objections can be raised,
and also does not say in express terms about the
filing of a written statement. Instead, the word
’shall’ is used clearly implying thereby that it
casts   a   duty   on   the   Court   to   perform   its
obligations in rejecting the plaint when the same
is hit by any of the infirmities provided in the
four   clauses   of   Rule   11,   even   without
intervention   of   the   defendant.   In   any   event,
rejection  of  the  plaint under Rule  11  does  not
preclude the plaintiffs from presenting a fresh
plaint in terms of Rule 13.”
11.From the afore-stated provisions contained in
Order VI Rule 2 and Order VII Rule 1 it clearly
emerges that the pleadings i.e. the plaint in the
instant case, must state the material facts
constituting the cause of action and as to when
it arose, and omission of a single material fact
leads to an incomplete cause of action, and the
plaint becomes bad. Such infirmity may attract
Clause (d) of Rule 11 of Order VII. The word
“shall” used in Order VII Rule 11 also cast duty
on the Court to reject the plaint when it is hit
by any of the clauses mentioned in Rule 11.

IN THE HIGH COURT OF GUJARAT AT AHMEDABAD
CIVIL REVISION APPLICATION NO. 10 of 2015

H D F C BANK LIMITED.VASHAPURA MINECHEM LIMITED..


CORAM:  MS.JUSTICE BELA M. TRIVEDI

Date : 13/10/2017
Read full judgment here: Click here
Print Page

No comments:

Post a Comment