Initial Settlement: On November 1, 2011, the family entered into an oral settlement where two daughters (appellants No. 2 and 3) received ₹9 crores each and relinquished their shares in the family properties in favor of their brother, S. Ramanathan (respondent No. 1).

The Power of Attorney (PoA): On November 4, 2011, M. Sokkalingam executed a registered PoA in favor of E.J. Ayyappan (respondent No. 2) for properties in Ooty and Pudukottai. Based on this, settlement deeds were executed in favor of the son (respondent No. 1).

The First Suit (O.S. No. 4722 of 2012): M. Sokkalingam and his wife filed a suit seeking a permanent injunction regarding a Chennai property and bank accounts, alleging the son had used intimidation and coercion to force them to execute documents.

The Second Suit (O.S. No. 2320 of 2013): After M. Sokkalingam died in 2013, his widow and daughters filed a second suit to declare the November 4, 2011 PoA as null and void, alleging it was obtained through fraud and coercion while Sokkalingam was semi-conscious.

Rejection of Plaint: The respondents filed an application under Order VII Rule 11 of the CPC, arguing the second suit was barred by Order II Rule 2 (which prevents splitting claims arising from the same cause of action). The Trial Court dismissed this application, but the High Court reversed it and rejected the plaint, prompting this appeal to the Supreme Court.

Distinction Between the Rules: The Court clarified that Order VII Rule 11(d) applies when a suit is “barred by any law” from being filed at all (e.g., limitation or express statutory bars like the SARFAESI Act). Conversely, Order II Rule 2 is a technical bar that prevents a plaintiff from seeking certain claims or reliefs that were omitted in a previous suit based on the same cause of action.

Evidence is Required for Order II Rule 2: A plea under Order II Rule 2 cannot be decided solely by reading the plaint; it requires a comparative analysis of the two plaints and often involves recording evidence to establish if the causes of action are truly identical. Therefore, it cannot be a ground for the summary rejection of a plaint under Order VII Rule 11(d).

Meaning of “Cause of Action”: The Court defined this as every fact necessary for the plaintiff to prove to support their right to judgment. It noted that even if two suits arise from the same transaction, they may have different causes of action if the required evidence for each is different.

Error by the High Court: The Supreme Court found that the High Court improperly analyzed the averments of the second suit as if they were evidence and strayed into the merits of the case rather than strictly following the procedural limits of Order VII Rule 11.