Judgment on Admissions Under Order XII Rule 6 CPC Is Discretionary and Requires Clear, Categorical Admission of Facts

The petitioner (plaintiff) filed a civil suit in 2022 for partition and permanent injunction regarding properties belonging to her late father, Harbhajan Singh Chhadda

The respondents (defendants) filed a written statement denying the averments and raising objections regarding jurisdiction, limitation, and non-joinder of necessary parties

On May 10, 2023, the Trial Court framed eight issues based on the pleadings

Simultaneously, the petitioner moved an application under Order XII Rule 6 of the CPC seeking a partial decree based on the respondents' purported admission that the parties are legal heirs entitled to shares in a specific house property (J-113, Adarsh Nagar)

The Trial Court dismissed this application on October 1, 2024, leading the petitioner to challenge the dismissal under Article 227 of the Constitution

1. Whether the respondents’ admission of the familial relationship and status as legal heirs constitutes a "clear, unequivocal, and unconditional admission" sufficient to grant a judgment under Order XII Rule 6 CPC

2. Whether the High Court should interfere with the discretionary order of the Trial Court under its supervisory jurisdiction under Article 227

The Court primarily applied Order XII Rule 6 of the CPC, which grants discretionary power to the court to pronounce judgment on admissions that are clear, categorical, and unequivocal

It relied on Karan Kapoor v. Madhuri Kumar (2022) to establish that the provision is enabling/permissive ("may") rather than mandatory

It further cited Himani Alloys Limited v. Tata Steel Limited (2011) and Jeevan Diesels and Electricals Ltd. v. Jasbir Singh Chadha (2010), emphasizing that judgment on admission permanently denies a trial and must be used cautiously

The court also referenced Section 53 of the Bharatiya Sakshya Adhiniyam, 2023 (corresponding to Section 58 of the Evidence Act), noting that courts retain the discretion to require proof of admitted facts in the interest of justice

Principles of supervisory jurisdiction under Article 227, as laid down in Sadhana Lodh v. National Insurance Co. (2003), were applied to limit interference to cases of patent error or jurisdictional overreach

The Court reasoned that for Order XII Rule 6 to apply, the admission must not be read in isolation but in the context of the entire pleading

Although the respondents admitted the petitioner’s status as a legal heir, they simultaneously pleaded the existence of a family settlement and a release deed dated September 3, 2020, which disputed the extent of her actual rights

The framing of eight distinct issues by the Trial Court—including those on limitation, valuation, and the validity of the release deed—demonstrated that substantial disputed questions of fact and law exist

The High Court observed that a "roving enquiry" at an interlocutory stage is impermissible, and when objections go to the root of the case, the Court must exercise its discretion to refuse a summary decree to protect the defendant's right to a trial

Applying the standard for Article 227, the Court found no perversity or jurisdictional error in the Trial Court’s decision to proceed to a full trial

The Court affirmed that the power under Order XII Rule 6 is purely discretionary and should not be exercised when serious questions of law and fact (like the validity of a release deed) require evidence

Consequently, the High Court dismissed the writ petition and upheld the Trial Court’s order dated October 1, 2024, directing the lower court to decide the suit expeditiously