"Order XII Rule 6 CPC: Supreme Court Rules That Judgments Cannot Be Based on Unclear or Conditional Admissions"

Recently, the Supreme Court ruled that under Order XII Rule 6 of the Civil Procedure Code, 1908 (CPC), a judgment cannot be based on unclear or ambiguous admissions. The court noted that if an admission contains both legal and factual issues, it cannot be considered a proper admission under Order XII Rule 6. The purpose of this rule is to speed up the resolution of cases in certain situations. However, the court warned that unless the admission is clear, unambiguous, and unconditional, judges should avoid using this rule since judgments made on admissions are issued without a full trial, which could prevent the involved parties from challenging the case later on. The case involved a landlord seeking to evict tenants, arguing that under the West Bengal Premises Tenancy Act, 1997 (the "New Act"), the tenants couldn't stay beyond five years after their mother's death in 2009. The tenants, however, claimed they inherited the tenancy rights much earlier, in 1970, based on the previous West Bengal Premises Tenancy Act, 1956 (the "Old Act"). A lower court, relying on statements the tenants made in a different case, ruled against them under Order XII Rule 6 CPC, a decision that was upheld by the High Court. But the Supreme Court overturned these judgments, explaining that the supposed admission by the tenants wasn't a proper one. The Supreme Court stated that an admission that goes against the law or contradicts legal rights cannot be considered valid. Since the Old Act's rights couldn't be taken away by the New Act unless explicitly stated, the tenants' claim under the Old Act remained valid. The court concluded that the admission in the other case was not clear or straightforward enough to be used against the tenants in the present case. It stressed that not every statement made in court counts as an admission under Order XII Rule 6 CPC, and each case's specific facts must be considered to decide if a statement can be treated as a clear admission. Case: RAJESH MITRA @RAJESH KUMAR MITRA & ANR. VERSUS KARNANI PROPERTIES LTD., CIVIL APPEAL NOS. 3593-3594 OF 2024 www.legalmeet.in