Critical Appreciation of Section 12-A(1) of Commercial Courts Act, 2015 through Legal Fiction
By

-- Saurabh Sharma, Advocate --


“Laws are effective when individuals abide by them or, alternatively, when they do not, but have to face legal sanctions for their non-compliance.”[1]

--- Judith Hahn ---

The whole purpose of enforcing Commercial Courts Act, 2015 was to improve the ease of doing business and the economy of the country. The concept of pre-litigation mediation is another step in that direction. Section 12A of the Commercial Courts Act, 2015 deals with the procedure of pre-litigation mediation and reads as under:

“Section 12A: Pre-Institution Mediation and Settlement. 12A. (1) A suit, which does not contemplate any urgent interim relief under this Act, shall not be instituted unless the plaintiff exhausts the remedy of pre-institution mediation in accordance with such manner and procedure as may be prescribed by rules made by the Central Government.”[2]

In practice, an application under Section 12-A of the Commercial Courts Act, 2015 is filed before the Incharge, Mediation Center of the District which has territorial jurisdiction over the subject –matter of the case and Notice of Mediation proceedings is issued to the Opposite Party. Thereafter, fate of the mediation proceedings depends entirely on the attitude of the Opposite party.

Legal Fiction-I

A, a businessman has to recover a sum of Rs. XYZ/- from another businessman B for a commercial transaction; and files an application under Section 12-A of the Commercial Courts Act, 2015 before the Incharge, Mediation Center concerned. Three times Notice is issued to B by the Incharge, Mediation Centre. B receives all the three Notices and chooses not to respond to it or appear before the Mediation Centre on the next date of hearing. What option does A have?

A has no other option but to obtain a Non-starter report from the Mediation Centre and file a Commercial Suit before the Principal Judge, Commercial Courts. A files a Commercial Suit for Recovery of the dues against B. Court issues summons to B. B receives the summons; but this time, he appears before the court; because he is aware that in case of his non-appearance before the court, Court may proceed ex-parte and eventually pass a decree against B.

Observation:

No businessman wants to take resort to litigation in the first instance. It is only when he gives up on the opposite party and loses all hope to recover the dues that he engages a lawyer to set the legal ball rolling. Before enforcement of the Commercial Courts Act, 2015, like any other civil suit, A would have filed a civil suit for Recovery in the court of Principal Judge of the courts having pecuniary and territorial jurisdiction; Summons of the case would have been served upon B and it is very unlikely of him to not appear before the court of law to defend the civil suit for recovery; or chose to have the court proceed ex-parte against him.

The process of issuance and serving of the Mediation Notices upon the opposite party takes one month to three months’ time depending on the mode of execution of service of notices and the rigidity of the Incharge, Mediation center with respect to the satisfaction of the proof of service of the notices of the Mediation Centre. The process of issuance and service of court summons also takes similar time. There is no accountability for the time lost in the futile exercise of service of notice of Mediation upon B before filing of the commercial suit in the court of law. B chose not to join the mediation proceedings because he knew that no adverse action can be taken against him for non-appearance. Section 12-A of the Commercial Courts Act, 2015 is a toothless piece of legislation; which in the above-mentioned scenario might prove to be a waste of time, energy and money of the Claimant/Plaintiff and the court machinery.

Legal Fiction-II

A, a businessman has to recover a sum of Rs. XYZ/- from another businessman B for a commercial transaction; but his claim is hopelessly time barred. Now, A having no option to take the legal recourse by way of filing a civil suit; pays a prescribed nominal fee and files an application under Section 12-A of the Commercial Courts Act, 2015 before the Incharge, Mediation Center concerned. In a routine and mechanical manner, Three times Notice is issued to B by the Incharge, Mediation Centre. B receives the Notice. What option does B have?

Observation:

B will participate in the Mediation proceedings and will incur time, money and energy in explaining to the Mediator, how A’s claim is time-barred; to which the Mediator may or may not agree depending on his legal expertise. The Mediator might persuade B to pay something to A just to bury the hatchet. If B pays some amount to A, then A would recover an amount which legally he could never recover from B.

Even if B does not join the mediation proceedings, A might obtain a non-starter report from the Mediation Center and file a commercial suit for recovery deriving a lame cause of action from the date of non-starter report.

Conclusion:

The law is still evolving. Problems in applying the law were inevitable. Nevertheless, The courts are pro-actively taking note of such difficulties such as the decision of Hon’ble Delhi High court in the case of Kapil Goel v. Ram Dulare Yadav @Gandhi Bhai (2022/DHC/004923)[3]. Mere enactment will not serve the purpose; rather the procedure of implementation should also serve the object of the Commercial Courts Act. There has to be check and balance mechanism at the stage of filing of the Application under Section 12-A of the Commercial Courts Act, 2015; so that no one can misuse the Legal Machinery for his vested interests. On the other hand, a non-starter report should also culminate into a presumption against the opposite party during the trial; in case of non-appearance of the opposite party despite proof of service of the Notice of the Mediation Centre.

_______________



[1] Foundations of a Sociology of Canon Law by Judith Hahn (pp 179–222).

[2] The Commercial Courts Act, 2015 enacted on 23rd October 2015

[3] (2022/DHC/004923).


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