Chhattisgarh High Court

TRIAL COURT MUST FRAME ADDITIONAL ISSUES ON MATERIAL FACTS PLEADED REGARDING TERMINATION OF CONTRACT IN SPECIFIC PERFORMANCE SUITS.

MEYALI KUTTI vs YOGESH PANDEY

Chhattisgarh High CourtJUDGMENT: May 06, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner (Defendant No. 1) entered into an agreement for sale dated 03.02.2022 with Respondent No. 1 (Plaintiff) regarding land in village Kurud

Source reference: p. 2

The Petitioner contended that since the Plaintiff failed to perform his part of the contract within the stipulated one-year period, the Petitioner served a legal notice on 07.03.2023 revoking/terminating the agreement

Source reference: p. 2

In the trial court (8th District Judge, Durg), the Petitioner moved an application under Order 14 Rule 5 of the CPC to frame an additional issue regarding the service and effect of the termination notice

Source reference: p. 2-3

The trial court rejected this application via an order dated 07.04.2026

Source reference: p. 1
02

Issues

1. Whether the trial court erred in refusing to frame an additional issue regarding the service and legal effect of the termination notice dated 07.03.2023.

Source reference: p. 3 / para. 6-7
03

Law Applied

Order 14 Rule 5 of the Code of Civil Procedure (CPC), which empowers the court to amend issues or frame additional issues at any time before passing a decree if such issues are necessary for determining the matters in controversy between the parties

Source reference: p. 3

Foundational principle of civil procedure that issues must be framed based on the "rival pleadings" of the parties to ensure an effective adjudication of the dispute

Source reference: p. 4

Article 227 of the Constitution of India

Source reference: p. 2
04

Reasoning

The High Court observed that the Respondent No. 1 (Plaintiff) had specifically pleaded in paragraph 8 of the plaint that the notice dated 07.03.2023 could not legally cancel the agreement

Source reference: p. 3

The Petitioner (Defendant No. 1) asserted in the written statement that the contract stood terminated by the said notice

Source reference: p. 3

The Court reasoned that since the executability and subsistence of the agreement are the "root of the case," the question of whether the agreement was validly cancelled constitutes a "triable issue"

Source reference: p. 3

The Court found that while the trial court had framed general issues, it failed to frame a specific issue regarding the effect of the March 2023 notice, which is essential for a comprehensive adjudication of the rights of the parties

Source reference: p. 3-4
05

Holding

The High Court concluded that a proper adjudication was not possible without the proposed issue

The High Court partly allowed the petition and directed the trial court to frame the additional issue as proposed in paragraph 1-A of the Petitioner’s application and proceed with the suit by providing both parties an opportunity to lead evidence on that specific point

Source reference: p. 4
Chhattisgarh High Court

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MEYALI KUTTIvsYOGESH PANDEY

Chhattisgarh High Court · May 06, 2026

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