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P.J. Sikand (also known as Paramjeet Singh) vs. Guruji Ka Ashram Trust and Ors.

Civil Miscellaneous (Main) Petition (IPD) · 2026:DHC:8283Decided 23 Sept 2026New Delhi Bench
CM(M)-IPD 51/2026CNR: DLHC010455062026
Justice Purushaindra Kumar Kaurav

Background

Guruji Ka Ashram Trust, a charitable trust associated with the late spiritual figure "Guruji," sued P.J. Sikand for allegedly infringing copyright in Guruji's photographs, copying the trust's temple ("Bade Mandir") design at a structure in Sri Ganganagar, Rajasthan called "Guruji Ka Darbar," and soliciting donations using Guruji's name. Sikand's application to dismiss the suit at the threshold (under Order VII Rule 11 CPC, for allegedly disclosing no cause of action) was rejected by a District Judge, and Sikand challenged that rejection before the High Court under Article 227 of the Constitution.

Decision Breakdown

The High Court emphasised that its supervisory power under Article 227 is narrow: it cannot act like an appeal court reweighing evidence, especially against interlocutory commercial-court orders where ordinary revision is barred by the Commercial Courts Act. Reviewing the trial court's reasoning, it agreed that most of Sikand's objections (validity of a copyright assignment deed, alleged prior settlement, limitation, territorial jurisdiction) were genuine defences to be tested at trial, not grounds to reject the plaint outright, since the plaint, taken at face value with its supporting documents, did disclose a cause of action. The petition was accordingly dismissed, leaving all issues open for trial.

Lesson Learnt

An application to dismiss a lawsuit at the very outset (for "disclosing no cause of action") is not a shortcut to argue the merits of your defence, as long as the plaintiff's own pleadings and documents show a plausible legal claim, the case must go to trial rather than be thrown out early.

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