JSA Prism | Dispute Resolution | October 2025

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Telangana High Court clarifies uniform applicability of the 2018 amendment to the Commercial Courts Act, 2015 across India without the requirement of a separate State notification to its effect

The High Court of Telangana (“Telangana HC”) in the case of M/s. Janset Labs Private Limited vs. Agilent Technologies Private Limited[1] held that the amended ‘specified value’ threshold of INR 3,00,000 (Indian Rupees three lakh) under Section 2(1)(i) of the Commercial Courts Act, 2015 (“CC Act”) (as amended under the Commercial Courts (Amendment) Act, 2018, (“CC Amendment Act”)) applies uniformly across India, including Telangana, without requiring a separate State Government notification. The Telangana HC clarified that ‘specified value’ under Section 2(1)(i) of the CC Act (which determines whether a dispute is commercial) is distinct from ‘pecuniary jurisdiction’ under Section 3(1A) of the CC Act (which defines the monetary limits of courts within a State) and held that the requirement of a notification under Section 3(1A) cannot be imported into Section 2(1)(i).

Brief facts

Agilent Technologies India Private Limited (“Respondent”) filed a commercial suit (“Commercial Suit”) in the Commercial Court, Ranga Reddy District at L.B. Nagar (“Commercial Court”) against M/s. Janset Labs Private Limited (“Petitioner”). The Commercial Suit was filed for recovery of a total amount of INR 1,03,58,961 (Indian Rupees one crore three lakh fifty-eight thousand nine hundred and sixty-one), consisting of the principal amount of INR 44,53,396 (Indian Rupees forty-four lakh fifty-three thousand three hundred and ninety-six) along with interest at 18% per annum and damages.
The Petitioner filed an interim application (“Rejection of Plaint”) in the Commercial Suit under Order VII Rule 11(d) of the Code of Civil Procedure, 1908 (“CPC”) to dismiss the Commercial Suit on the ground that the suit does not meet the ‘specified value’ provided under Section 2(1)(i) of the CC Act i.e. INR 1,00,00,000 (Indian Rupees one crore) and stated that the amendment under Section 2(1)(i) of the CC Amendment Act reducing the threshold of the “specified value” to INR 3,00,000 (Indian Rupees three lakh) is not applicable in Telangana due to the lack of state notification to its effect. Additionally, the Petitioner contended that segregation of damages is not permissible for computing of the ‘specified value’.
The Commercial Court dismissed the Rejection of Plaint on the ground that the plaint discloses cause of action for filing of the Commercial Suit (“Impugned Order”).
Aggrieved by the Impugned Order, the Petitioner filed the instant Civil Revision Petition (“CRP”) before the Telangana HC arguing that the ‘specified value’ of the Commercial Suit is below INR 1,00,00,000 (Indian Rupees one crore). As such, it does not satisfy the threshold provided under Section 2(1)(i) of the CC Act and must be dismissed. Additionally, it was contended by the Petitioner that the reduced ‘specified value’ of INR 3,00,000 (Indian Rupees three lakh) provided under Section 2(1)(i) of the CC Amendment Act is not applicable in the State of Telangana in the absence of a State notification.

Issues

Whether the amended specified value of INR 3,00,000 (Indian Rupees three lakh) under Section 2(1)(i) of the CC Amendment Act applies to Telangana without a separate State Government notification?
Whether ‘specified value’ under Section 2(1)(i) of the CC Act is distinct from the ‘pecuniary jurisdiction’ prescribed under Section 3(1A) of the CC Act?
Whether the plaint was liable to be rejected under Order VII Rule 11(d) of CPC for want of jurisdiction?

Findings and analysis

The Telangana HC observed that the ‘specified value’ under Section 2(1)(i) as determined by Section 12 of the CC Act is not less than INR 3,00,000 (Indian Rupees three lakh) pursuant to the CC Amendment Act. The Petitioner’s contention that a separate notification is required by State Government for its application in Telangana was dismissed since the statute confers power only on the Central Government to notify a higher threshold. Therefore, the reduction of the minimum specified value from INR 1,00,00,000 (Indian Rupees one crore) to INR 3,00,000 (Indian Rupees three lakh) as per the amendment applies uniformly to all States and Union Territories without the need for separate State notification.
The Telangana HC further went on to analyze the distinction between ‘specified value’ and ‘pecuniary jurisdiction’ and opined that Section 2(1)(i) of the CC Act refers to the valuation of the commercial dispute to determine whether the dispute qualifies as a commercial dispute at all. It observed that a dispute falls within the jurisdiction of the commercial court if there is: (a) existence of dispute as per Section 2(1)(c) of the CC Act; and (b) the commercial dispute is within the ‘specified value’ under Section 2(1)(i) r/w Section 12 of the CC Act. In contrast, Section 3(1A) of the CC Act fixes the competence-parameters of the court for receiving a commercial suit, meaning whether or not that particular court has the jurisdiction to determine the dispute.
The Telangana HC noted that the requirement of notification by the State Government in Section 3(1A) of the CC Act cannot be read into or imported under Section 2(1)(i). Thus, Telangana does not require any separate notification and the amended INR 3,00,000 (Indian Rupees three lakh) threshold is applied with effect from May 3, 2018.
Given the above, the Petitioner’s contention on segregation of prayers is irrelevant since the dispute falls under the ‘specified value’ of INR 3,00,000 (Indian Rupees three lakh) or more. Accordingly, the CRP was dismissed.

Conclusion

The Telangana HC reaffirmed that the CC Amendment Act operates uniformly across India, including Telangana, without the need for a separate State notification. By clarifying the distinction between ‘specified value’ and ‘pecuniary jurisdiction’, the Telangana HC provided crucial interpretative clarity and reinforced the uniform national applicability of the amended INR 3,00,000 (Indian Rupees three lakh) threshold for commercial disputes.

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