Thursday, 5 September 2024

Supreme Court: Money Recovery Suit Won't Be Commercial Suit Unless Disputed Property Is 'Actually Used' In Trade and Commerce

 The above issue was considered in Ambalal Sarabhai Enterprises

Limited v. K.S. Infraspace LLP & Anr. reported in (2020) 15 SCC 585 where the implication of Section 2(1)(c)(vii) was construed. In

the concurring judgment, the following was expressed by Justice

Banumathi:

“37. A dispute relating to immovable property per se

may not be a commercial dispute. But it becomes a

commercial dispute, if it falls under sub-clause

(vii) of Section 2(1)(c) of the Act viz. “the

agreements relating to immovable property used

exclusively in trade or commerce”. The words “used

exclusively in trade or commerce” are to be

interpreted purposefully. The word “used” denotes

“actually used” and it cannot be either “ready for

use” or “likely to be used” or “to be used”. It

should be “actually used”. Such a wide interpretation

would defeat the objects of the Act and the fast

tracking procedure discussed above.” {Para }

 S U P R E M E C O U R T O F I N D I A

 RECORD OF PROCEEDINGS

SPECIAL LEAVE PETITION (CIVIL) Diary No(s). 2986/2024

S.P. VELAYUTHAM & ANR. Vs M/S EMAAR MGF LAND LIMITED.

CORAM : HON'BLE MR. JUSTICE HRISHIKESH ROY

 HON'BLE MR. JUSTICE PRASHANT KUMAR MISHRA

 Date : 26-02-2024 .

 UPON hearing the counsel the Court made the following

 O R D E R

Delay stand condoned as there have been several litigation

including in this Court in pursuant to the impugned order that was

passed by the learned Single Judge of the High Court on 04.12.2018.

2. Heard Mr. P.S. Patwalia, learned senior counsel appearing for

the petitioners (defendants in the C.S. No. 169 of 2018). Also


heard Mr. Gopal Sankaranarayanan learned senior counsel appearing

for the respondent (plaintiff in the C.S. No. 169 of 2018).

3. The primary challenge in these Special Leave Petitions is to

the order dated 04.12.2018 whereunder, the learned Judge of the

High Court held that the C.S. No. 169 of 2018 filed by the

respondent-plaintiff is a commercial suit, within the meaning of

Section 2(1)(c) of the Commercial Courts Act, 2015. The Court

justified its decision, inter alia, by citing the ratio in Jagmohan

Belal v. State Bank of Indore (decided on 22.09.2017), Monika Arora

v. Neeraj Kohli in CM(M) No. 850 of 2016 (decided on 01.09.2016)

and Soni Dave v. Trans Asian Industries Expositions Pvt. Ltd.

reported in AIR 2016 Del 186.

4. On the other hand, to argue that this was a simple money

recovery suit and cannot therefore be treated as a commercial suit,

the defendants relied on the Gujarat High Court decision in Vasu

Healthcare Private Limtied v. Gujarat Akruti TCG Biotech Limited

reported in (2017) AIR (Gujarat) 153.

5. It is argued with some emphasis by the defendants that it is

only a Suit for recovery of money and if the view in the impugned

judgment is accepted as correct, all money recovery suits will

travel towards the commercial division and it will defeat the very

purpose of creating the commercial divisions, to fast track

commercial category suits. In support of such contention, the

counsel would rely on sub-clause (vii) of Section 2(1)(c) to say

that the concerned agreements must pertain to immovable property

used exclusively in trade or commerce. According to Mr. Patwalia,

the agreements relate to properties which were not used exclusively

for trade or commerce but there could possibly be use of such

property in future, for commercial purpose.

6. Per contra, Mr. Gopal Sankaranarayanan, learned senior counsel

would refer to the explanation in Section 2(1)(c)(vii) in the above

context to say that a commercial dispute shall not cease to be a

commercial dispute merely because the suit pertains to realisation

of money.

7. The above issue was considered in Ambalal Sarabhai Enterprises

Limited v. K.S. Infraspace LLP & Anr. reported in (2020) 15 SCC 585 where the implication of Section 2(1)(c)(vii) was construed. In

the concurring judgment, the following was expressed by Justice

Banumathi:

“37. A dispute relating to immovable property per se

may not be a commercial dispute. But it becomes a

commercial dispute, if it falls under sub-clause

(vii) of Section 2(1)(c) of the Act viz. “the

agreements relating to immovable property used

exclusively in trade or commerce”. The words “used

exclusively in trade or commerce” are to be

interpreted purposefully. The word “used” denotes

“actually used” and it cannot be either “ready for

use” or “likely to be used” or “to be used”. It

should be “actually used”. Such a wide interpretation

would defeat the objects of the Act and the fast

tracking procedure discussed above.”

8. As is seen, the above judgment in Ambalal was pronounced only

on 04.10.2019 and well before that, the impugned judgment was

rendered by the learned Single Judge on 04.12.2018.

9. The counsel for the rival parties therefore submit that the

learned Single Judge of the High Court should be permitted to 

decide on whether the Suit should be treated as a commercial

dispute, within the meaning of Section 2(1)(c).

10. Accepting the above submission particularly in light of ratio

in Ambalal, we deem it appropriate to set aside the impugned

judgment of the learned Judge of the High Court rendered on

04.12.2018 in the CS No. 169 of 2018. The matter is remitted back

to the High Court to re-decide on whether the Suit for recovery of

money would fall within the category of cases covered under Section

2(1)(c)(vii) of the Commercial Courts Act, 2015. With this order,

the Special Leave Petitions stand disposed of.

11. Pending application(s), if any, shall stand closed.

(NITIN TALREJA) (KAMLESH RAWAT)

ASTT. REGISTRAR-cum-PS ASSISTANT REGISTRAR


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