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Supreme Court of India 2020-06-05 allowed

Shakti Bhog Food Industries Ltd vs The Central Bank of India & Anr

Bench: 3 — A.M. Khanwilkar, Indira Banerjee, Dinesh Maheshwari

In Brief

Shakti Bhog Food Industries challenged the rejection of its plaint seeking accounts rendition and recovery of excess bank charges. The trial court, first appellate court, and High Court rejected the plaint as time-barred under Article 113 of the Limitation Act, 1963. The Supreme Court held that the plaint disclosed multiple accruals of cause of action and could not be rejected at the threshold stage. The Court emphasized that Article 113's generic expression 'when the right to sue accrues' (distinct from 'first accrues' in other articles) applies to continuing breaches. The entire plaint must be read together; selective reading is impermissible. Whether limitation applies in such cases involves mixed fact-and-law questions unsuitable for threshold rejection. The plaint was restored to the trial court for hearing on merits.

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Civil Procedure Limitation Plaint Rejection Cause of Action

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