Commercial Litigation in Noida and Greater Noida: Jurisdiction, Mediation and the Allahabad High Court Route

By Bhaskar Subramanian, Partner, S&S Co. Advocates & Solicitors and Adv. Anupam, Senior Associate, S&S Co. Advocates & Solicitors

Published 28 October 2026 · Law stated as on 26 October 2026 · Informational content, not legal advice: see our disclaimer

A supplier in Sector 63 who is owed four crore rupees by a contractor in Greater Noida cannot simply walk into the nearest civil court and file a suit the way a litigant could twenty years ago. The Commercial Courts Act, 2015 has rerouted that suit through a specific court, a mandatory mediation step and a set of procedural stages that did not exist before 2015, and Gautam Buddh Nagar has its own notified structure for all of this.

A district with its own commercial court, and why that matters

Gautam Buddh Nagar is not a bystander to India's commercial court reform. The district was among the thirteen in Uttar Pradesh where the state government, after consulting the Allahabad High Court, notified commercial courts under government orders dated 31 October 2017 and 2 November 2017, exercising the power given to it by Section 3(1) of the Commercial Courts Act, 2015. That original notification gave the Gautam Buddh Nagar commercial court territorial jurisdiction extending beyond its own district, covering Hapur and Ghaziabad as well.

The arrangement did not stay static. A further notification dated 21 July 2022 created additional commercial courts in Meerut, Gautam Buddh Nagar, Agra and Lucknow. When that notification reached the Supreme Court in connection with a separate dispute, the Court flagged a structural problem: the new courts appeared to carry jurisdiction over different sets of districts than the courts created in 2017, which risked confusion and delay for litigants trying to work out which bench actually had their case. The matter was listed for further hearing, and litigants in Gautam Buddh Nagar should treat the point as one to verify against the current cause list rather than assume it is settled for good.

What is clear on the ground is that Gautam Buddh Nagar today has more than one commercial court sitting at the district court complex in Surajpur, Greater Noida, each with its own presiding officer and court number. An Allahabad High Court posting order dated 9 January 2023 moved a presiding officer from 'Commercial Court, Court No. 2, Gautam Buddh Nagar' to 'Commercial Court, Court No. 1, Gautam Buddh Nagar,' which confirms at least two numbered commercial courts functioning in the district by that date. A business filing a commercial suit needs to check the current roster, since misfiling before the wrong numbered court within the same complex causes delay even though it does not usually raise a jurisdictional defect of the kind that would see the suit thrown out.

What actually counts as a 'commercial dispute'

Not every dispute between businesses in Noida is a commercial dispute for the purposes of the Act. Section 2(1)(c) sets out a closed list of categories, numbering twenty-two in the current text, and a claim has to fit within one of them before the special procedure applies at all. The first and most frequently invoked category covers ordinary transactions of merchants, bankers, financiers and traders, including transactions involving mercantile documents such as promissory notes, bills of exchange and letters of credit. Other categories reach construction and infrastructure contracts including tenders, franchising and distribution agreements, joint venture and shareholder arrangements, intellectual property disputes, and insurance and reinsurance.

Immovable property gets a category of its own, but courts have read it narrowly. The requirement is that the property be actually used exclusively in trade or commerce, not merely intended or suitable for such use. A warehouse let out to a logistics company and in active commercial use at the time the dispute arises fits the description; a plot bought as an investment and lying vacant, or residential property, generally does not, whatever commercial ambitions the owner may have had for it. The Telangana High Court has gone further and said each sub-clause of Section 2(1)(c) must be construed strictly and purposively, looking for a transaction whose effect reaches beyond the two contracting parties into the wider commercial sphere, rather than simply any dealing that happens to involve money changing hands between businesses.

Once a dispute qualifies as commercial, it must also cross the specified value threshold to land in the commercial court rather than an ordinary civil court. The 2018 amendment to the Act lowered this floor from one crore rupees to three lakh rupees, letting state governments fix a figure for all or part of the state at not less than three lakh rupees. Two state High Courts have recently taken up the question of whether this change is self-operative. In May 2026, a full bench of the Andhra Pradesh High Court held, by a two-to-one majority, that the three-lakh floor took effect directly from the 2018 amendment without needing any separate state notification, reasoning that a fresh notification is required only if the central government later wants to fix a higher figure. The dissenting judge on that bench accepted the lower figure as a statutory fact but held that the reduction alone does not automatically shift pecuniary jurisdiction to the commercial courts; the Telangana High Court earlier drew a related distinction, treating the specified value (which decides whether a dispute is commercial at all) as a separate question from pecuniary jurisdiction (which decides which particular court within a state hears it). Businesses in Gautam Buddh Nagar with claims in the three-lakh-to-one-crore range should get specific advice on which of these readings the Allahabad High Court has adopted, since the answer decides whether their suit belongs before the commercial court or the ordinary civil court down the corridor.

Section 12A mediation: the mandatory first step

Before a commercial suit that does not contemplate urgent interim relief can even be filed, Section 12A of the Act requires the prospective plaintiff to attempt pre-institution mediation. The Supreme Court settled the mandatory character of this requirement in Patil Automation Private Limited v. Rakheja Engineers Private Limited (2022) 10 SCC 1, holding that a suit instituted in breach of Section 12A is liable to be rejected under Order VII Rule 11 of the Code of Civil Procedure. The Court limited this consequence prospectively, applying it to suits filed on or after 20 August 2022, the date of its judgment, while suits filed earlier in breach of the provision were to be kept in abeyance pending mediation rather than rejected outright. In 2025, in Dhanbad Fuels Private Limited v. Union of India, a Supreme Court bench reaffirmed this mandatory reading and worked through the consequences of giving Patil Automation prospective effect for suits caught at the boundary.

The mediation itself runs through the authority constituted for the purpose under the relevant rules framed for the state, generally staffed by legal services authorities, and is meant to conclude within three months of the plaintiff's application, extendable by a further two months if both parties consent. A plaintiff in Gautam Buddh Nagar should build this window into any litigation timeline from the outset: a dispute that looks urgent in commercial terms, such as a cash-flow crunch caused by non-payment, does not automatically qualify for the urgent-relief exception, and a failed attempt to invoke that exception can cost several months before the suit is even on file.

The exception itself has been narrowed by the Supreme Court's decision in Yamini Manohar v. T.K.D. Keerthi, reported as 2023 LiveLaw (SC) 906, which rejected the idea that a plaintiff can defeat Section 12A simply by including a prayer for urgent interim relief in the plaint. The Court held that a commercial court examining an Order VII Rule 11 application must look at the plaint's pleadings and the underlying facts to see whether the case genuinely contemplates urgent relief, intervening to require mediation only where the claim of urgency is a sham, in the Court's words something as plain as 'deception and falsity apparent or established.' In the case itself, the Supreme Court accepted that the pleadings supported the urgency claimed and allowed the suit to proceed without mediation. A 2024 Allahabad High Court decision applied the same test to reject a plaintiff's attempt to dress up an ordinary payment dispute as one requiring urgent relief, sending the parties back to mediation. The lesson for a Gautam Buddh Nagar business is that the urgency exception survives scrutiny only when the plaint itself, read on its own terms, shows a real and specific need for interim protection, such as a threatened sale of specific assets or an imminent limitation bar, rather than the generalised urgency that attends most commercial disputes between unpaid creditors and reluctant debtors.

Filing the suit: territorial jurisdiction and the paperwork that follows

Territorial jurisdiction for a commercial suit still runs on the ordinary civil law rules in Sections 15 to 20 of the Code of Civil Procedure, read together with any jurisdiction clause in the parties' contract. A suit ordinarily lies where the defendant resides or carries on business, or where the cause of action, wholly or in part, arose. For a Noida-based business dealing with a counterparty elsewhere in the country, this usually means the suit can be filed in Gautam Buddh Nagar if the contract was performed there, payment was due there, or the defendant has a place of business there, even if the defendant is based outside Uttar Pradesh. Many commercial contracts also include an exclusive jurisdiction clause naming a particular court; such clauses are enforced, provided the named court is one that would independently have jurisdiction under the Code, since parties cannot confer jurisdiction on a court that has none. A clause naming 'the courts at Noida' without more detail invites argument over whether it means Gautam Buddh Nagar's civil courts generally or its commercial court specifically, and businesses drafting fresh contracts do better to name the district by its official name, Gautam Buddh Nagar, and to state expressly that the clause covers commercial disputes of the specified value falling under the Commercial Courts Act.

Valuation of the suit for the purposes of court fees and for deciding whether the specified value is met deserves separate attention from valuation for the purposes of the underlying claim. The Act defines specified value by reference to the market value of the subject matter, which for a money claim is ordinarily the amount claimed, but for a claim involving immovable property or specific performance can require a distinct valuation exercise under the applicable court fees legislation. A plaintiff who undervalues the suit to save on court fees risks a defendant raising an objection that the true specified value falls below the commercial court threshold, which, if accepted, sends the matter to the ordinary civil side and effectively restarts the clock on mediation, case management and the rest of the commercial procedure. Getting the valuation right at the drafting stage, with supporting material on file to justify the figure if challenged, avoids this entirely preventable detour.

Once filed, the suit proceeds under the amended Code of Civil Procedure provisions that apply specifically to commercial suits, including a stricter regime for filing documents, affidavits of admission and denial, and disclosure. The Order XI mechanism requires both sides to disclose relevant documents early and with specificity, and a party that fails to disclose a document it later wants to rely on faces real difficulty introducing it afterward. Defendants get thirty days from service of summons to file a written statement, extendable to a maximum of one hundred and twenty days only on payment of costs, after which the right to file a written statement is forfeited; this is considerably tighter than the regime for an ordinary civil suit and catches out defendants and their counsel who are used to the more relaxed timelines outside the commercial courts system.

The centrepiece of the procedural reform is the case management hearing under Order XV-A, which the court must hold within four weeks of the affidavits of admission and denial being filed. At this hearing the court is expected to frame issues, fix a timetable for evidence, and set firm dates for written and oral arguments, with the stated aim of ensuring that arguments close within six months of the first case management hearing. In practice, the extent to which Gautam Buddh Nagar's commercial courts hold to this timetable varies, and parties should treat the statutory timeline as the standard to insist on at each hearing rather than something that enforces itself. Where a lessor's claim for possession is also in play, litigants should be careful to distinguish this Order XV-A, introduced for commercial suits, from an entirely separate Bombay (Maharashtra) state amendment to the Code that also uses the number Order XV-A but deals with striking off a tenant's or licensee's defence in a lessor's suit for eviction or rent; the two provisions share a number but serve unrelated purposes, and confusing them in pleadings or arguments is a avoidable error.

Summary judgment: when a trial can be skipped

Order XIII-A, introduced specifically for commercial suits, lets a party apply for summary judgment without a full trial once summons has been served but before issues have been framed. The standard is whether the opposing party has no real prospect of succeeding on the claim or defence, and whether there is no other compelling reason for a trial to proceed. This is a meaningful departure from the ordinary civil procedure, where a defendant who files any written statement at all is usually guaranteed a trial regardless of how weak the defence looks on paper.

The Supreme Court gave this provision sharper teeth in Reliance Eminent Trading and Commercial Private Limited v. Delhi Development Authority, reported as 2026 INSC 436, where it urged commercial courts to 'grasp the nettle and decide' summary judgment applications rather than deferring them to trial out of habit, particularly where the dispute turns on a neat point of law or contractual construction rather than contested facts. The Court treated the provision as a genuine tool for weeding out speculative defences, applicable where the foundational facts of the dispute are themselves undisputed between the parties. Separately, the Supreme Court has made clear in the context of the Commercial Courts Act generally that a party cannot resist timely compliance, including at the summary judgment stage, merely by pointing to the volume of documents in the case; 'too many documents' is not an acceptable excuse for delay or for avoiding an application properly made.

A defendant facing a summary judgment application in Gautam Buddh Nagar needs a response that goes beyond bare denial. Where documents central to the claim, such as invoices, delivery challans or acknowledgment letters, have already been admitted in the pleadings or in the Order XI disclosure process, a defendant cannot treat admission of the documents as separate from admission of the liability that flows from them; courts have scrutinised this gap closely, since a party sometimes accepts that a document exists and is genuine while still disputing what obligation it actually creates. A business considering an Order XIII-A application, whether as plaintiff seeking a quick decree or as defendant resisting one, should map out exactly which facts are genuinely contested and which are not, since the provision rewards precision about that distinction far more than it rewards general argument about the merits.

Appeals: Section 13, the sixty-day clock, and the road to Prayagraj

An appeal from a decree or order of the Gautam Buddh Nagar commercial court lies under Section 13 of the Act, and for orders that would otherwise be appealable under the Code of Civil Procedure or under Section 37 of the Arbitration and Conciliation Act, 1996, the Act carries its own limitation period. Section 13(1A) sets this at sixty days from the date of the judgment or order, a markedly shorter window than the ninety days generally available under the Limitation Act, 1963 for a regular first appeal. The Supreme Court has confirmed that this sixty-day period applies uniformly to appeals against orders passed under Section 37 of the Arbitration Act where those orders arise from a commercial dispute of the specified value.

Because Gautam Buddh Nagar falls within the Principal Seat of the Allahabad High Court at Prayagraj rather than within the Lucknow Bench's territorial jurisdiction, a commercial appeal from the district goes to Prayagraj. A litigant used to dealing with the Lucknow Bench for other kinds of civil or criminal work in western Uttar Pradesh should not assume the same forum applies to a commercial appeal; the correct seat has to be confirmed district by district, and Gautam Buddh Nagar sits with the principal seat.

The sixty-day limitation period is not absolute, but the room to extend it is narrow by design. In a 2021 decision, a three-judge bench of the Supreme Court comprising Nariman, Gavai and Roy JJ overruled the Court's own earlier ruling in N.V. International, which had held that no delay beyond a combined period could ever be condoned, and confirmed instead that Section 5 of the Limitation Act, 1963 does apply to appeals under Section 13 of the Commercial Courts Act, so that a genuine case of sufficient cause can still secure condonation. The Court was emphatic, however, that this relief is the exception and not the rule, available only for a short delay where the appellant has acted bona fide throughout, and that 'sufficient cause' is not elastic enough to excuse a long delay measured in months rather than days. Later decisions applying this standard have refused condonation where the explanation offered was internal departmental delay or the time taken to obtain internal approvals, treating these as ordinary administrative friction rather than genuine impediments beyond the appellant's control. A Gautam Buddh Nagar litigant who misses the sixty-day window should instruct counsel to start preparing the condonation application, with a day-by-day account of the delay, from the moment the window is missed, rather than waiting until the appeal itself is ready to file.

When the dispute runs through the Noida or Greater Noida Authority instead

A sizeable share of commercial disputes touching Gautam Buddh Nagar do not pit one private business against another at all, but involve the New Okhla Industrial Development Authority, the Greater Noida Industrial Development Authority, or the Yamuna Expressway Industrial Development Authority, as a party to a lease, allotment or development agreement. Because these are statutory development authorities exercising public functions and controlled by the state government, the Allahabad High Court has repeatedly entertained writ petitions under Article 226 of the Constitution challenging their decisions to cancel a plot allotment, terminate a lease, or demand additional charges, treating these as actions of a public authority amenable to judicial review rather than purely private contractual disputes to be fought out in a civil suit.

A representative recent example is the Allahabad High Court's handling of a challenge to a 7 November 2024 order cancelling the lease and allotment of an institutional plot in Sector 1, Noida for an alleged breach of the lease terms. The petitioner approached the High Court directly under Article 226 rather than filing a civil suit, and the Court disposed of the petition by directing the Authority to review its own cancellation order, while granting interim protection against coercive recovery action in the meantime. This pattern, of a writ petition rather than a suit being the vehicle of first resort against the development authorities, recurs across allotment and cancellation disputes in the district, and the Supreme Court has itself observed that the allotment of land and plots in planned townships of this kind has generated what it called innumerable controversies and 'huge litigation' before the Allahabad and Delhi High Courts and the Supreme Court itself.

None of this means every dispute with a development authority bypasses the commercial courts. Where the underlying relationship is genuinely contractual, for instance a construction or supply contract with the Authority that falls within one of the Section 2(1)(c) categories and meets the specified value, a commercial suit remains available and is often the more appropriate route, particularly where damages rather than quashing of an administrative order is the real relief sought. The two routes also interact at the level of natural justice: the Supreme Court has set aside cancellation orders where the authority acted without giving the affected party notice and a hearing, a principle that applies whichever forum reviews the decision. A business dealing with one of the Noida-area authorities should work out early, with counsel, whether its grievance is best framed as a public-law challenge to an administrative decision or as a private commercial claim, since the choice affects the forum, the available remedies, and the time limits that apply.

A practical sequence for a business bringing or defending a claim

A business in Noida or Greater Noida contemplating a commercial claim should work through a defined sequence rather than rushing straight to a plaint. The first step is confirming that the dispute actually fits a Section 2(1)(c) category and meets the specified value, since getting this wrong risks a rejection or a transfer to the ordinary civil side after months have already passed. The second is deciding, honestly, whether the facts support a genuine claim of urgency; a party that overstates urgency to dodge mediation and is caught out by the Yamini Manohar test loses more time than one that simply completes the mediation process in parallel with preparing the suit.

The third step is assembling the documentary record with the Order XI disclosure obligations already in mind, since documents not disclosed early are difficult to introduce later, and a party that is scrupulous about disclosure from the outset is also better placed to bring or resist a summary judgment application under Order XIII-A. The fourth is treating the case management hearing as a working session to be prepared for rather than a formality, since the dates fixed there, for evidence, for written arguments and for final hearing, are meant to bind the parties for the rest of the suit's life. The fifth is calendaring the sixty-day appeal window from day one of any adverse order, since the gap between the ordinary ninety-day civil appeal period and the sixty-day commercial appeal period is a trap that catches litigants and counsel who are not used to working under the Commercial Courts Act.

For a dispute that instead involves the Noida, Greater Noida or Yamuna Expressway development authorities, the equivalent first step is identifying whether the grievance is genuinely a challenge to administrative action, suited to a writ petition, or a contractual claim for money or specific relief, suited to a civil or commercial suit, and building the record, including any representations made to the Authority and its response, accordingly from the start. Businesses that treat these as alternative routes to be chosen deliberately, rather than defaulting to whichever their counsel happens to be more familiar with, tend to get to a resolution faster and with fewer false starts.

A sixth and often neglected step is keeping a clear internal record of who within the business corresponded with the counterparty, and when, since commercial disputes frequently turn on whether a demand was made, a defect was notified within the time the contract allowed, or a waiver was granted informally over email or on a call. Gautam Buddh Nagar's commercial courts, like commercial courts elsewhere, expect parties to plead specific dates and specific documents rather than general narratives, and a business that can hand its lawyer a clean, dated record of the relationship has a real head start at every one of the stages described above, from the mediation session through to a case management hearing and, if it comes to that, a summary judgment application.

Getting paid: executing a decree once the suit is won

Winning a commercial suit in Gautam Buddh Nagar is not the end of the matter if the losing party does not pay voluntarily. A money decree is executed under Order XXI of the Code of Civil Procedure, and the decree-holder can attach and sell the judgment debtor's movable or immovable property, attach bank accounts, or seek arrest and detention in limited circumstances where the debtor has the means to pay and wilfully refuses. For a judgment debtor whose assets sit outside Gautam Buddh Nagar, perhaps a factory in Ghaziabad or a bank account in Delhi, the decree-holder generally applies under Section 39 of the Code for the Gautam Buddh Nagar commercial court to transfer the decree for execution to the court within whose limits those assets are situated; this is routine practice rather than a separate suit, but it still takes time, and a decree-holder should file the transfer application promptly rather than waiting to see if the judgment debtor pays voluntarily.

A practical point many businesses overlook is that execution itself attracts its own procedural safeguards for the judgment debtor, including objections under Section 47 of the Code and, where the decree is challenged as having been obtained by fraud or without jurisdiction, a right to raise that challenge even at the execution stage. A decree-holder should expect execution to take real time even after winning on merits, and should start identifying the judgment debtor's attachable assets, through pre-decree disclosure, bank statements obtained during the suit, or independent inquiry, well before the decree is actually passed, rather than beginning that search only once execution proceedings are filed.

Costs are a further point worth factoring into the overall calculation before a business decides to litigate at all. The commercial courts regime, unlike much of ordinary civil practice in India, is meant to apply a more realistic costs rule, under which an unsuccessful party can be made to bear a meaningful share of the successful party's actual litigation expense rather than the nominal costs that civil courts have traditionally awarded. In practice, Gautam Buddh Nagar's commercial courts do not always apply this rule with the rigour the statute contemplates, and a business should treat a costs order in its favour as a welcome bonus rather than a reliable source of recovery, while still raising a properly particularised costs claim at the end of the suit so the point is at least on record for any appeal.

Where the position remains unsettled

Two points deserve a flag rather than a firm answer. The first is the exact interaction between the specified-value question and pecuniary jurisdiction following the 2018 amendment: the Andhra Pradesh High Court's May 2026 full bench ruling that the three-lakh floor is self-operative is recent, came by a divided majority, and has not yet been tested before the Allahabad High Court or the Supreme Court on an appeal from Uttar Pradesh; a Gautam Buddh Nagar litigant with a claim in the lower band of this range should seek a current opinion on how the Allahabad High Court is actually applying the distinction rather than relying on the Andhra Pradesh position by analogy.

The second is the durability of the 2022 notification creating additional commercial courts in Gautam Buddh Nagar and three other districts, given the Supreme Court's own observation that the notification appeared to assign overlapping or inconsistent district jurisdictions and its decision to keep the matter pending for further hearing. Until that is resolved, or at least clarified through practice, litigants and their counsel should verify, case by case, which numbered commercial court in the district actually has seisin of a particular matter, rather than assuming the position has settled permanently in the way the 2017 notification did.

The Commercial Courts Act has given Gautam Buddh Nagar's business community a procedure that is faster on paper than ordinary civil litigation, with mandatory mediation meant to filter out disputes that never needed a court at all, case management hearings meant to keep the ones that remain on a schedule, and summary judgment meant to dispose of the ones that do not genuinely need a trial. Whether that promise is delivered in a given case depends heavily on how carefully a business and its counsel use each of these stages rather than treating them as paperwork to get past on the way to an eventual trial.

The shorter appeal clock and the split between the commercial litigation route and the writ route against the development authorities are the two features of practice in this district that most often catch businesses by surprise. Building both into a dispute strategy from the outset, rather than discovering them after a deadline has passed or after a suit has been filed in the wrong form, remains the most reliable way to use the system as it was designed to work.

Frequently Asked Questions

References & Further Reading

The provisions, rulings and official documents below were relied on for this article, which states the law as on 26 October 2026. The position can change with amendments, rules and later decisions, so check the current text before acting on any of it.

1. Commercial Courts Act, 2015, Sections 2(1)(c), 3, 3(1A), 12A, 13, 13(1A), 16, 21
2. Commercial Courts, Commercial Division and Commercial Appellate Division of High Courts (Amendment) Act, 2018
3. Code of Civil Procedure, 1908, Order XI, Order XIII-A, Order XV-A, Sections 15-20
4. Limitation Act, 1963, Section 5
5. Uttar Pradesh Government Order dated 31 October 2017 and 2 November 2017 notifying commercial courts in thirteen districts including Gautam Buddh Nagar
6. Uttar Pradesh Government Notification dated 21 July 2022 creating additional commercial courts at Meerut, Gautam Buddh Nagar, Agra and Lucknow
7. Allahabad High Court Notification Nos. 12 to 14 dated 9 January 2023 (posting of Presiding Officer, Commercial Court, Gautam Buddh Nagar)
8. Patil Automation Private Limited v. Rakheja Engineers Private Limited, (2022) 10 SCC 1
9. Dhanbad Fuels Private Limited v. Union of India, 2025 INSC (Supreme Court, on prospective application of Patil Automation)
10. Yamini Manohar v. T.K.D. Keerthi, 2023 LiveLaw (SC) 906
11. Reliance Eminent Trading and Commercial Private Limited v. Delhi Development Authority, 2026 INSC 436
12. Supreme Court of India, order dated 16 August 2022 in SLP(C) No. 7090 of 2022 (commercial courts notification, Uttar Pradesh)
13. N.V. International v. State of Assam, (2020) 2 SCC 109 (overruled on the point of condonation beyond the Section 13(1A) period)
14. Supreme Court of India, decision overruling N.V. International on condonation of delay under Section 13, Commercial Courts Act (2021), per Nariman, Gavai and Roy JJ
15. Supreme Court of India, ruling that 'too many documents' is not sufficient cause for delay under the Commercial Courts Act
16. Allahabad High Court, order on review of plot allotment cancellation, Sector 1, Noida (writ petition under Article 226, 2024-25)
17. Telangana High Court, ruling on purposive construction of Section 2(1)(c), Commercial Courts Act, 2015
18. Andhra Pradesh High Court, Full Bench ruling (2:1), May 2026, on self-operative application of the three-lakh-rupee specified value threshold
19. Code of Civil Procedure, 1908, Order XXI, Sections 38, 39, 47

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