When can a plaint be rejected as “barred by law”?

The Supreme Court clarified that limitation and ownership questions are often mixed issues of law and fact; they cannot be decided at the threshold. The Court restored the trial court’s decision, emphasizing that a suit for possession based on title carries a 12-year limitation under Article 65 of the Limitation Act.

Key Takeaways :

✅ Limited scope of Order 7 Rule 11(d) CPC

✅ Mutation entries do not confer ownership.

✅ Limitation question involves mixed fact and law.

✅ Possession - based suits have 12 - year limitation.

✅ Multiple - relief principle - If a suit involves multiple reliefs and any one of them is within limitation, the plaint cannot be rejected in entirety under Order 7 Rule 11(d).

✅ Error by the High Court

✅ Outcome : appeals allowed.

Statutes:

1. CPC, 1908 – Order 7 Rule 11, Order 2 Rule 2

2. Limitation Act, 1963 – Articles 58 & 65

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