Tuesday 5 January 2021

Section 16: Suits to be instituted where subject-matter situate

Code of Civil Procedure Section 15. Court in which suits to be instituted.

16. Suits to be instituted where subject-matter situate.—Subject to the pecuniary or other limitations prescribed by any law, suits—

(a) for the recovery of immovable property with or without rent or profits,

(b) for the partition of immovable property,

(c) for foreclosure, sale or redemption in the case of a mortgage of or charge upon immovable property,

(d) or the determination of any other right to or interest in immovable property,

(e) for compensation for wrong to immovable property,

(f) for the recovery of movable property actually under distraint or attachment, shall be instituted in the Court within the local limits of whose jurisdiction the property is situate:

Provided that a suit to obtain relief respecting, or compensation for wrong to, immovable property held by or on behalf of the defendant may, where the relief sought can be entirely obtained through his personal obedience, be instituted either in the Court within the local limits of whose jurisdiction the property is situate, or in the Court within the local limits of whose jurisdiction the defendant actually and voluntarily resides, or carries on business, or personally works for gain.

Explanation.—In this section “property” means property situate in 1[India].

Note 1: Subs. by Act 2 of 1951, s. 3 for “the States”

Part in Red is original provisions from CPC reproduced here for reference.

Code of Civil Procedure Section 17. Suits for immovable property situate within jurisdiction of different Courts.



Simplified Explanation:
Section 16 provides for institution of the suit where subject matters are situated. As per this section, the suit must be instituted where subject matter is situated.
It states for the various suits for immovable property (Clause (a) to (e)) and movable property (Clause (f)).
Suits regarding immovable property such as recovery of immovable property with or without rent or profit, partition of immovable property, foreclosure, sale or redemption of mortgage immovable property, compensation for wrong to immovable property etc. as well as suit regarding the recovery of movable property under distraint or attachment can be instituted at
a) a relevant Court having local limits of its jurisdiction where such property is situated; e.g. if the property is situated at Delhi then such suits shall be instituted at Court in Delhi and not at any other place. or
b) a relevant Court having local limits of its jurisdiction where the defendant actually or voluntarily resides or carries business or works for gain; e.g. the defendant resides in Mumbai then the suit against his can be filed at Court in Mumbai and not at any other place.
It should be noted that this section applies to any property situated within the territory of India (Bharat).

Judgment:

(a) In Aligarh Muslim University v. Vinay Engineering Enterprises Pvt. Ltd., (1994) 4 SCC 710, the Supreme Court examined a case wherein the contract between the parties was executed at Aligarh; the construction work was to be carried out at Aligarh; the contract provided that in the event of dispute, Aligarh Court alone would have the jurisdiction; the arbitrator was to be appointed at Aligarh and had to function at Aligarh. The Supreme Court held that the Court at Calcutta had no jurisdiction, because the respondent company was a Calcutta-based firm.

(b) In Board of Trustees for the Port of Calcutta v. Bombay Flour Mills Pvt. Ltd. & Anr., AIR 1995 SC 577, the Supreme Court considered a case wherein a civil court at Bharatpur (Rajasthan) entertained a civil suit in respect of assignment of imported goods unloaded at Calcutta dock and the plaintiff’s representation to the Port Trust to waive the port charges had been refused. The Civil Court at Bharatpur entertained the suit and passed an ex parte ad-interim mandatory injunction directing the Port Trust to release the goods on payment of specified amount. The Rajasthan High Court dismissed the appeal of the Port Trust, but the Supreme Court held that as no cause of action, even partly, occurred at Bharatpur, the only appropriate court at Calcutta was competent to take cognizance of the action and held that the orders of the Civil Court at Bharatpur, having no jurisdiction, were void and the order of the High Court, refusing to interfere with the orders, was illegal.

(c) In H.V. Jayaram v. Industrial Credit & Investment Corpn. of India Ltd., AIR 2000 SC 579, the Supreme Court examined the issue of territorial jurisdiction of a court in respect of the offence under Section 113 (2) of the Indian Companies Act, 1956. Taking note of Sections 113 and 207 of the said Act, the Apex Court held that the cause of action for default of not sending the share certificates within the stipulated period would arise only at a place where the registered office of the company was situated as from that place the share certificates could be posted and are usually posted.





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