2024 SCC Online SC 3844 (Sri Mukund Bhavan Trust v. Shrimant Chhatrapati Udayan Raje Pratapsinh Maharaj Bhonsle) - The Supreme Court held that the rejection of a plaint on the grounds of limitation involves a mixed question of fact and law, and such decisions must be carefully scrutinized. The Court emphasized that limitation is a mixed question, and rejection of plaint under Order VII Rule 11 should be based on clear legal and factual grounds. The judgment also clarified that the Court is mindful of the legal principles governing limitation and jurisdictional issues reference: sources 04300050672, N. Kempaiah Since Deceased by His LRs. Smt. M. Bhagyalakshmi vs A.V. Srinivas Since Deceased by His LRs. Smt. M. Kalpana - Karnataka, Gowramma, W/O Sri Tyagarajareddy vs Susheelamma - Karnataka, - Madras, Mountain Spinning Mills Ltd. vs Arasan - Madras.
Legal Precedents and Principles - The Court referred to earlier judgments, including Revajeetu Builders and Developers v. Srei Ultra Infra Ltd., to underscore that questions of limitation are inherently mixed questions of law and fact, requiring thorough examination before dismissing a plaint. It also highlighted that the Court's jurisdiction under Order VII Rule 11 is limited and must be exercised with caution reference: sources 00300053391, Sushrutha Vishranthi Dhama Pvt. Ltd. vs M.P. Somaprasad S/o M.K. Prabhakaharan - Karnataka.
Implications on Limitation and Jurisdiction - The judgment clarifies that the determination of limitation involves factual assessment and legal interpretation, and courts should not dismiss plaint solely on limitation grounds without proper inquiry. The Court reaffirmed that jurisdiction under Order VII Rule 11 is not to be exercised lightly, especially when facts are in dispute reference: sources 00300053191, Gowramma, W/O Sri Tyagarajareddy vs Susheelamma - Karnataka.
Related Cases and References - The judgment cites cases like Ramathal and others v. K. Rajamani, and others, as well as earlier Supreme Court rulings, to reinforce the principles governing limitation, jurisdiction, and the rejection of plaints. It also discusses the importance of proper fact-finding before dismissing a suit on limitation grounds reference: sources 04300050672, - Madras.
Analysis and Conclusion:
The 2024 Supreme Court judgment in SCC Online 3844 emphasizes that rejection of a plaint on the ground of limitation must involve a careful, fact-based inquiry, considering the mixed nature of the question. Courts are cautioned against dismissing suits prematurely under Order VII Rule 11 without proper factual and legal analysis. This decision reinforces the importance of thorough examination of limitation issues, ensuring that jurisdictional and substantive rights are protected. The judgment aligns with established legal principles and prior rulings, emphasizing judicial prudence in such matters.
Shrimant Chhatrapati Udayan Raje Pratapsinh Maharaj Bhonsle and another, 2024 SCC OnLine SC 3844 and Ramathal and others v. K. Rajamani (Dead) through LRs. and another, 2023 SCC OnLine SC 1022. 10. ... The Hon’ble Apex Court in Sri Mukund Bhavan Trust v. Shrimant Chhatrapati Udayan Raje Pratapsinh Maharaj Bhonsle and another, 2024 SCC OnLine SC 3844 held that: “12. ... Rajamani (Dead) through LRs.....
... ... Result: The plaint in O.S.No.356 of 2024 is hereby rejected. ... 17.The Hon'ble Supreme Court in a judgment reported in 2024 SCC Online SC 3844 ( Shri Mukund Bhavan Trust and others Vs. ... Hemant Kumar Jalan and others ); 2024 SCC Online SC 3844 ( Shri Mukund Bhavan Trust and others Vs. Shrimant Chhatrapati Udayan Raje Pratapsinh Maharaj Bhonsle and another ) and a href="./.. ... 19.The Hon'ble Supreme Court in a judgmen....
... ... Result: CRP No.434/2024 dismissed; W.P.No.19689/2024 allowed; CRP No.204/2024 allowed; plaint rejected. ... Shrimant Chhatrapati Udayan Raje Prathapsinh Maharaj Bhonsle and another , (2024) SCC OnLine SC 3844 where it was held that though it is a settled position of law that limitation is a mixed question of fact and law and the question of rejecting the plaint on that score has to be decided ... Kalsmmanavara Kalamma (Since Dead) by Legal heirs and others, (....
SHRIMANT CHHATRAPATI UDAYA RAJE PRATAPSINGH MAHARAJ BHONSLE & ANOTHER - 2024 SCC Online SC 3844 has held in paragraphs 16 and 18 as under: "16. ... METROPOLI OVERSEAS LIMITED & OTHERS -2022 SCC Online SC 2024 11. ... Heard the learned counsel Sri. Yeshu Baba R Mishra., for the plaintiff/appellant and the learned counsel Sri. Arjun P.K., for the defendant No.5/respondent No.5.
Heard Sri G.Sundaresan, learned counsel for the petitioners and Sri M.Vivekananda Reddy, learned Assistant Public Prosecutor for respondents-State. 9. ... Criminal Petition No.3844 of 2025: This Criminal Petition is filed by the petitioner/accused No.8 to quash the proceedings against him in C.C.No.5 of 2014 pending on the file of the Principal Junior Civil Judge-Cum-Judicial Magistrate of First Class, Hanumakonda. ... , learned Assistant Public Prosecutor for respondents-State opposed the submissions of learned counsel for the petitione....
(2021) 16 SCC 768 “11. ... Heard learned senior counsel Sri Srinivas Raghavan for the petitioner/ defendant No.6, learned counsel Sri G.Balakrishna Shastry for respondent No.1, learned counsel Sri H.C.
Chhatrapati UdayanRajePratapsinh Maharaj Bhonsle, (2024) 15 SCC 675 : 2024 SCC OnLine SC 3844] to substantiate the contention that the suit was barred by limitation. It was observed as follows : (SCC paras 22 & 25) [2024 SCC OnLine SC 3846] , has held as follows: “…. …. …. 28. This Court in Revajeetu Builders and Developers v. ... HITESH P.SANGHVI, [2025 SCC OnLine SC 779], has h....
K.Umar Khan and others); (2022) 12 SCC 641 ( Rajendra Bajoria and others Vs. Hemant Kumar Jalan and others); 2024 SCC Online SC 3844 (Shri Mukund Bhavan Trust and others Vs. ... 17.The Hon'ble Supreme Court in a judgment reported in 2024 SCC Online SC 3844 (Shri Mukund Bhavan Trust and others Vs. ... 19.The Hon'ble Supreme Court in a judgment reported in 2023 SCC Online SC 521 (Ramisetty Venkata....
Shrimant Chhaptrapati Udayan Raje Pratpsinh Maharaj Bhonsle and Another , reported in, (2024) SCC Online SC 3844; (ii) Shabeer (Dead) through Lrs Vs. ... P.Narayanaan and others , reported in (2025) SCC Online 975 and Ramilaben Devji Jodhani Vs. Ishvarlal Mangnlal Sha , reported in AIR Online 2023 Guj 1515. He would therefore pray for dismissal of the revision petition. ... Vinod Kumar Sharma and others , reported in (2017) SCC Online#HL_E....
Shrimant Chhatrapati Udayan Raje Pratapsinh Maharaj Bhonsle and Another , 2024 SCC OnLine SC 3844, the Hon’ble Apex Court in paragraph 26 has held that, it is not unmindful of the position of law that limitation is a mixed question of fact and law and the question ... Prajapati Kodarbhai Kachrabhai and Another , 2024 SCC OnLine SC 4105 where it was held that there was no jurisdiction for the High Court in allowing the application under Order VII Rule 11, on issues tha....
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