T Arivandanam v T.V. Satyapal (1977) 4 SCC 467

This case shows how courts should deal with frivolous suits. If the plaint—read fairly and as a whole—does not show a real right to sue, the court must reject it under Order 7 Rule 11 CPC at the threshold.

• Key idea: No cause of action = instant rejection.
• Method: Use a meaningful, not mechanical, reading of the plaint.
• Goal: Stop abuse of process and save time.

1. What should courts do to curb frivolous and vexatious cases?
2. When can a plaint be rejected for want of a cause of action under Order 7 Rule 11 CPC?

• Order 7 Rule 11 CPC: If the plaint does not disclose a cause of action, the court shall reject it.
• Meaningful reading test: Look beyond clever wording; ask if any prayed relief can legally be granted from the plaint itself.
• Early filter: If no relief is possible, dismiss at the first hearing to prevent misuse.

• Meaningful reading: Look at the plaint practically; if it is plainly meritless, reject it.
• Order 7 Rule 11 CPC: Use this power at the outset when no clear right to sue is shown.
• Abuse of process: Courts must be firm with vexatious litigation.

Pleadings must reveal a real cause of action. If a meaningful reading shows none, the plaint must be rejected under Order 7 Rule 11 CPC at the very start.

• Saves judicial time by stopping hopeless suits early.
• Protects parties from harassment via repeated, copycat litigation.
• Provides a clear test for trial courts: the meaningful reading standard.

• 1 Courts must reject sham plaints at the threshold (O7 R11).
• 2 Apply a meaningful reading—substance over form.
• 3 If no relief is legally possible from the plaint, dismiss at first hearing.
• 4 Curb abuse of process and forum shopping.

Mnemonic: “READ REAL, REJECT SHAM.”

• READ REAL → Meaningful reading of the plaint.
• REJECT → Use O7 R11 where no cause exists.
• SHAM → Clever drafting cannot create rights.

3-Step Hook:

1. Ask: Do plaint facts, as stated, create a legal right?
2. Check: Is any prayed relief grantable in law?
3. Decide: If not, reject the plaint at once.

Order 7 Rule 11 CPC

Rule that lets a court reject a plaint for reasons like no cause of action.

Cause of Action

Set of facts giving a legal right to sue.

Meaningful Reading

Reading pleadings practically to see real substance, not wordplay.

Abuse of Process

Using court procedures unfairly to delay or harass.