Case Title: Nupur Mehta v. Bennett Coleman and Company Ltd. and Others
Order Date: 11 September 2025
Case Number: CS(OS) 376/2025
Court: High Court of Delhi
Hon’ble Judge: Hon’ble Ms. Justice Manmeet Pritam Singh Arora
Facts
The plaintiff, Nupur Mehta, filed a suit seeking permanent and mandatory injunctions as well as compensation for violation of her image rights and defamation caused by the defendants, which included Bennett Coleman and Company Ltd. The suit was filed in the High Court of Delhi and valued at a total of Rs. 10 crores for the purposes of pecuniary jurisdiction.
The suit included various prayer clauses, such as:
- Injunctions restraining the defendants from disseminating defamatory content;
- Removal of the defamatory video from social media;
- Compensation for slander and defamation; and
- A prayer for rendition of accounts for illegal use of the plaintiff’s image rights.
The plaintiff’s original pleadings valued the suit at Rs. 10 crores but sought to pay only a fixed court fee of Rs. 200 on certain reliefs, notably on the prayer for rendition of accounts, contending that it was a nominal sum for court fee purposes while maintaining a high valuation for jurisdictional purposes. This raised the question whether the plaintiff was liable to pay court fees ad valorem on the full valuation of Rs. 10 crores or the nominal amount of Rs. 200 stated for certain reliefs.
Procedural Details
The suit was initially listed before the High Court on 29 May 2025, where the court directed the plaintiff to pay court fees on the full valuation of Rs. 10 crores within four weeks, warning that the suit would be rejected otherwise. The plaintiff sought to amend the plaint to clarify the valuation and to pay court fees as per the re-assessed value.
Subsequently, an application for amendment was allowed on 8 August 2025, permitting the plaintiff to introduce a prayer for rendition of accounts.
The amended plaint maintained a valuation of Rs. 10 crores for jurisdiction but insisted on paying nominal court fees of Rs. 200 for rendition of accounts while pleading to pay ad valorem fees on ascertainment of damages. This dichotomy invited judicial scrutiny into the compatibility of such valuation with court fee statutes and the appropriate fee liability on rendition of accounts as relief.
Dispute
The central dispute before the court was whether a plaintiff seeking rendition of accounts and valuing the same for jurisdiction at Rs. 10 crores could be legally entitled to pay only a nominal court fee (Rs. 200) under Section 7(iv) of the Court Fees Act, 1870, or whether such relief warranted payment of court fee ad valorem based on the high valuation assigned for pecuniary jurisdiction.
The plaintiff relied on precedents including the Supreme Court judgment in Commercial Aviation and Travel Co. v. Vimla Pannalal (1988) 3 SCC 423 and a Full Bench judgment of the Delhi High Court in Sheila Devi and Others v. Kishan Lal Kalra and Others to argue that the court should not interfere with their valuation for the purpose of court fees. The plaintiff submitted that the valuation for rendition of accounts should follow the nominal fee pattern given the nature of the relief which is inherently unascertainable at the outset.
The court was tasked with reconciling the provisions of the Court Fees Act, 1870, the Suit Valuation Act, 1887, and relevant judicial precedents while addressing the potential tentativeness or alleged arbitrary nature of the plaintiff’s valuation and related court fee payment.
Detailed Reasoning and Legal Discussion
The court examined the interplay between two key statutory acts: the Court Fees Act, 1870, and the Suit Valuation Act, 1887. Section 7(iv) of the Court Fees Act provides for a fixed court fee for suits where the valuation of relief sought cannot be easily ascertained—such as in suits for rendition of accounts. This fixed fee was historically introduced to recognize the uncertainty in assessing exact damages at suit filing.
However, the Suit Valuation Act, 1887 governs pecuniary jurisdiction and requires the plaintiff to affix the value of the suit for determining appropriate jurisdiction of courts. The court emphasized that the value for court fees and for jurisdiction should align as per Section 8 of the Suit Valuation Act to ensure legislative coherence and practical administration of justice.
The court referred extensively to the Division Bench judgment in M/s Maiden Pharmaceuticals Ltd. v. M/s Wockhardt Ltd. (2008 SCC OnLine Del 804) which held that in suits for rendition of accounts, the valuation for jurisdiction dictates the court fee liability, and such valuation cannot be arbitrarily dissociated from court fees. This decision drew on the Supreme Court ruling in Commercial Aviation and Travel Co. which warned against whimsical and arbitrary valuation to evade payment of appropriate court fees, noting that a plaintiff must not “whimsically choose a ridiculous figure” when objective standards and positive materials exist in the plaint.
The court highlighted the rationale that while fixed court fees are a relief mechanism where suit valuation is uncertain, a plaintiff cannot exercise absolute discretion to assign a high jurisdictional value solely to secure filing in a higher court and then pay meagre court fees, thereby defeating statutory intent under Section 15 of the Code of Civil Procedure which mandates filing in the lowest competent court.
This dual valuation approach was found to be a misuse of jurisdictional criteria and court fees regulations. The court underscored the legislative mandate that court fees must correspond to the valuation affixed by the plaintiff for exercising pecuniary jurisdiction, thereby ensuring fairness and deterrence against vexatious litigation strategies.
The court also engaged prior judicial opinions specifying that the court may interfere in wrongful valuations not supported by positive records or objective standards and that plaintiffs having fixed arbitrary valuations must face consequences including potential dismissal or cost penalties.
The court pointed out that the plaintiff here afforded no coherent basis for valuing rendition of accounts relief at Rs. 10 crores while paying a nominal fee, especially since such value was aimed at invoking the jurisdictional threshold of the High Court.
The judgment further explained that rendition of accounts is a relief where exact damages are ascertainable only at a later stage, allowing the plaintiff some flexibility in nominal fee payment; yet this does not justify gross underpayment or decoupling from the valuation set for jurisdiction. It affirmed consistency with procedural rules laid down by the High Court under its rule-making powers.
Based on these principles, the court ruled that the plaintiff was liable to pay substantive ad valorem court fees on the valuation of Rs. 10 crores affixed for rendition of accounts relief and ruled against the appropriateness of merely nominal fee payment.
Decision
The court concluded that the plaintiff’s approach of valuing rendition of accounts for jurisdiction at Rs. 10 crores while paying fixed nominal court fees of Rs. 200 was legally impermissible. The plaintiff was held liable to pay ad valorem court fees consistent with the valuation for jurisdiction as per the Court Fees Act, 1870 and the Suit Valuation Act, 1887.
The court granted the plaintiff four weeks’ time to pay the requisite ad valorem court fees; failing which the suit would stand rejected under Order 7 Rule 11(b) of the Code of Civil Procedure. The court also reserved the right to impose deterrent costs against litigants engaging in arbitrary valuation tactics.
The court rejected the plaintiff’s submissions affirming binding precedents but clarified that valuations must not be whimsical or designed to circumvent statutory requirements on court fees.
