Delhi High Court Sets Aside Lower Court Order Rejecting Plaint In Dr. Mahender Prasad's Estate Dispute

In a significant judgment, the Delhi High Court has set aside an order by a Single Judge that had rejected a plaint filed by the legal heirs of Smt. Satula Devi, the wife of late Dr. Mahender Prasad, a former Member of Parliament. The Division Bench of Justices Anil Kshetarpal and Harish Vaidyanathan Shankar held that a plaint cannot be rejected in part and that a court must take a "holistic and pragmatic" view of the entire pleading, rather than focusing on isolated prayers.

The judgment, pronounced on September 16, 2025, consolidated and disposed of a batch of Letters Patent Appeals (LPAs), a First Appeal against Order (FAO), and a Regular First Appeal (RFA) that arose from a long-standing dispute over the estate of Dr. Mahender Prasad.

Case Background

The genesis of the litigation can be traced back to a Guardianship Petition filed by Smt. Satula Devi, seeking to manage the affairs of her husband, Dr. Mahender Prasad, who was suffering from "Frontotemporal Dementia." During the pendency of this petition, Dr. Prasad passed away on December 27, 2021.

Subsequently, a Probate Petition was filed by Smt. Kanchana Rai, claiming to be the executor of a registered Will allegedly executed by Dr. Prasad in 2011. In a parallel development, Smt. Satula Devi filed a separate suit seeking a declaration of ownership of the properties, claiming that the entire estate was built using her 'Stridhan' (a woman's property given at the time of marriage). She also sought to have the alleged Will declared null and void and for a partition of the properties. The Single Judge had rejected this plaint under Order VII Rule 11 of the Civil Procedure Code (CPC), holding it was not maintainable for various reasons, including lack of a cause of action and being barred by limitation.

High Court's Key Findings

The Division Bench systematically examined the grounds for the rejection of the plaint and made the following critical observations:

1. On Rejection of Plaint:

The Court emphasized that a plaint must be read in its entirety to determine if it discloses a cause of action. The Bench noted that the Single Judge had erred by focusing on specific prayers and averments in isolation. Citing well-established legal principles, the Court reiterated that a plaint cannot be rejected in part.

2. On Cause of Action & Limitation:

The Single Judge had held that the cause of action could not have arisen on the date of Dr. Prasad's death. The Division Bench, however, held that the plaintiff's cause of action to claim a share in her husband's properties would only arise upon the "opening of succession," i.e., upon his death. The Bench recorded a prima facie view that the suit was not barred by limitation.

3. On Reliefs Sought:

The Court noted that the plaintiff had sought a declaration and, in the alternative, a partition of the properties. The Bench clarified that while a Civil Court cannot examine the validity of a Will during the pendency of a Probate Petition, this does not bar a suit for partition. The Court can even "mould the relief" as long as the necessary court fees are paid.

4. On Contradictory Pleadings:

The Bench found that the defense of a "mutually destructive case" was not a valid ground for rejecting a plaint at the threshold, especially when the plaintiff had sought an alternative relief. Furthermore, the Court noted that a defense based on averments made in a previous writ petition could only be appropriately examined once evidence is presented by the parties.

5. Consolidation of Proceedings:

Given the interconnected nature of the disputes, the High Court directed the consolidation of the suit for declaration and partition with the pending Probate Petition. This move aims to streamline the litigation and prevent further procedural delays.

Final Order

The High Court set aside the Single Judge's order that had rejected the plaint. The Bench kept it open for the parties to file an application for amendment, make good any deficiency in court fees, or file an application under Order VI Rule 16 of the CPC. The Single Judge was also given the discretion to stay the proceedings if and when requested by the defendants. The parties have been asked to appear before the Single Judge on September 23, 2025, for further directions.

Please find a copy of the judgement here.