Order XII Rule 6 CPC: Court Cannot Decree a Suit by Reading One Line in Isolation: Supreme Court Says Admission Must Be Clear, Complete and Unconditional

Held: The Supreme Court held that a decree under Order XII Rule 6 CPC can be passed only where the admission relied upon is clear, categorical, unconditional and unequivocal. A court cannot isolate one sentence from a written statement and treat it as an admission of liability without reading the pleading as a whole. If the alleged admission requires interpretation, inference, examination of surrounding circumstances, or adjudication of disputed facts, the matter must proceed to trial. The Court further held that a decree on admission is an exception to ordinary civil trial because it denies the defendant an opportunity to contest the claim on merits, and therefore the discretion under Order XII Rule 6 CPC must be exercised cautiously.

Summary: The dispute arose within a Hindu family after agricultural land was sold for about INR 15.31 crore. Respondent No.1 filed a suit claiming recovery of INR 45 lakh, partition and injunction against her parents and siblings. Defendant No.3, predecessor of the appellants, stated in his written statement that under a family settlement he had received INR 3 crore out of the sale proceeds. After the High Court determined that each party had a 1/6th share, respondent No.1 filed an application under Order XII Rule 6 CPC contending that Defendant No.3 had received INR 44,79,167 more than his lawful share and therefore a decree should be passed against him on admission. The Additional District Judge rejected the application, holding that the dispute required trial. The High Court, in revision, reversed that order and decreed the suit against Defendant No.3. The Supreme Court held that the alleged statement was made in the context of a family settlement and did not amount to an admission that Defendant No.3 had received excess money or was liable to refund any amount to respondent No.1. The Court also noted that the entire sale consideration was received by respondent No.2, that the plaint sought joint and several reliefs, and that issues had already been framed for trial, showing existence of substantial triable questions.

Decision: The Supreme Court allowed the appeal, set aside the Delhi High Court judgment dated April 16, 2019 passed in Civil Revision Petition No. 53 of 2018, and restored the order dated December 20, 2017 of the Additional District Judge dismissing the application under Order XII Rule 6 CPC. The Court held that the High Court exceeded its limited revisional jurisdiction under Section 115 CPC by reassessing the pleadings and substituting its own view where the Trial Court had rightly found triable issues. It clarified that its observations were confined only to the Order XII Rule 6 issue and would not affect the merits of the pending civil proceedings, which the Trial Court must decide independently in accordance with law.