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TABLE OF CONTENTS
Inextricably linked disputes can be adjudicated along with the main 'commercial dispute' under the Commercial Courts Act, 2015
Manisha Gupta v. Rajinder Kumar
Second FIR is maintainable to uncover a broader criminal conspiracy
State of Rajasthan v. Surendra Singh Rathore
Insolvency of a member is not a ground to halt consortium-led projects
Three C Green Developers Pvt Ltd v. State of UP
LLP bound by arbitration clause despite not being signatory to the agreement
Kartik Radia v. BDO India LLP
3-fold test to determine the law governing an international arbitration clause
Disortho SAS v. Meril Life Sciences Pvt Ltd
Guidelines for determining compensation for land acquisition based on market value of adjacent land
Manilal Shamalbhai Patel v. Officer on Special Duty (Land Acquisition)
An unsigned arbitration clause is enforceable if the parties' conduct evidences consent
Glencore International AG v. SGM Metals
Non-compete employment clauses are not enforceable
Varun Tyagi v. Daffodil Software Pvt Ltd
Appointment of a sole arbitrator due to the other party's inaction is not invalid
St Frosso Shipping Corporation v. Eastern Multitrans Logistics Pvt Ltd
WhatsApp and email correspondence may constitute an arbitration agreement
Belvedere Resources DMCC v. OCL Iron and Steel Ltd
Likelihood of confusion is sufficient to protect a family of registered trademarks
Modi-Mundipharma Pvt Ltd v. Speciality Meditech Pvt Ltd
Civil Courts can grant anti-arbitration injunctions in foreign-seated arbitrations
Engineering Projects (India) Ltd v. MSA Global LLP
Registration alone may not confer a valid property title
K Gopi v. Sub-Registrar
NCLT is empowered to adjudicate on issues of fraud integral to oppression and mismanagement
Shailja Krishna v. Satori Global Ltd
Speculative investors can participate in but cannot initiate CIRP
Mansi Brar Fernandes v. Shubha Sharma
Inextricably linked disputes can be adjudicated along with the main 'commercial dispute' under the Commercial Courts Act, 2015
Manisha Gupta v. Rajinder Kumar
Delhi High Court | 2025 SCC OnLine Del 43
The Delhi High Court allowed ancillary disputes beyond the definition of 'commercial dispute' under Section 2(1)(c) of the Commercial Courts Act, 2015 (Act) to be included in a commercial suit if intrinsically linked to the principal dispute. Although the Supreme Court, in Ambalal Sarabhai Enterprises Ltd v. KS Infraspace LLP,1 held that the term 'commercial dispute' must be strictly construed to only cover transactions that are explicitly mentioned under its definition – in line with the purpose of the Act to facilitate the expeditious resolution of a class of litigation – the Delhi High Court's ruling carves out an exception. Since the principal dispute in the instant matter (partnership dispute) was explicitly covered under the Act and the interconnected transactions were essential to its resolution, such transactions, though not independently 'commercial disputes', would also be covered under the Act. Without diluting the Act's purpose, this decision prevents fragmentation and avoids conflicting outcomes that could arise if the interlinked disputes were adjudicated separately, ultimately streamlining commercial dispute resolution in line with the objective of the Act.
SUMMARY OF FACTS
Metal Industries, a partnership firm, was dissolved upon the death of one of its partners, Gopal Krishan Gupta.
Without settling accounts with Gopal's legal heir (his daughter, Manisha Gupta), the surviving partner, Rajinder Kumar (Defendant 1) set up a new firm on the same premises, appropriating the inventory and funds from the dissolved firm, Metal Industries.
Manisha alleged unauthorised dealings with Metal Industries' assets and funds by Defendant 1, aided by other Defendants, including relatives, employees/accountants, debtors, and creditors (Defendants 2 to 17) of Metal Industries.
In this regard, Manisha Gupta filed a suit under the Act seeking rendition of accounts, injunction, partition, and recovery concerning her late father's 50% share in the dissolved firm.
The maintainability of the Suit was opposed by Defendants 2 to 17 (non-partners) since their respective transactions with Metal Industries were not covered by the definition of 'commercial dispute' under Section 2(1)(c) of the Act.
DECISION OF THE COURT
The Court noted that though the dispute between Manisha and the surviving partner (Defendant 1) was admittedly covered by Section 2(1)(c) of the Act, the transactions between Metal Industries and the other Defendants were not.
Since the transaction between the creditors and the firm was commercial in nature as per Explanation II to Section 34 of the Code of Civil Procedure, 1908, despite not being covered by the definition of 'commercial dispute' under Section 2(1)(c) of the Act, the Suit was held maintainable against them.
Further, since the other Defendants also had direct privity with the partnership, having dealt with its funds and assets post-dissolution of Metal Industries, the legal heirs of the deceased partner have an undisputed right to seek verification of these transactions as they directly impact their share in the firm's assets.
Separating these claims into multiple proceedings would be inefficient, as the transactions were interconnected and required a comprehensive adjudication for the matter to be effectively resolved.
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Footnote
1. (2020) 15 SCC 585
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