Patil Automation Private Limited v. Rakheja Engineers Private Limited Citation: (2022) 10 SCC 1

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Patil Automation Private Limited v. Rakheja Engineers Private Limited

Citation: (2022) 10 SCC 1

🔹 Why It Is Important in Order 7 Rule 11 Context?

This judgment is primarily on Section 12A of the Commercial Courts Act, 2015 (Pre-Institution Mediation), but it directly impacts Order 7 Rule 11(d) CPC.

✅ Core Issue:

Whether filing a commercial suit without mandatory pre-institution mediation is maintainable?

🔹 Supreme Court Held:

  1. Section 12A is mandatory (not directory).

  2. If plaintiff files commercial suit without first exhausting pre-institution mediation (where no urgent interim relief is sought),
    👉 the plaint is liable to be rejected.

  3. Such rejection is under Order 7 Rule 11(d) — “suit barred by law”.

🔹 Ratio in One Line (Exam Ready):

Non-compliance with mandatory pre-institution mediation under Section 12A Commercial Courts Act renders the plaint liable to rejection under Order 7 Rule 11(d) CPC.

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