Rajdev Steels Wins Rs 63.6 Lakh Recovery Suit Against Bawa Appliances; Chhattisgarh Commercial Court Awards Interest and Costs

May 5, 2026 : The Commercial Court at Nava Raipur Atal Nagar has decreed a commercial recovery suit in favour of Rajdev Steels & Alloys Pvt. Ltd., directing Uttar Pradesh-based Bawa Appliances to pay an outstanding amount of Rs 63.60 lakh along with pendente lite and future interest. The court held that the plaintiff had successfully established the supply of sponge iron materials and the defendant’s liability to clear the unpaid dues arising out of commercial transactions.

The judgment was delivered by Commercial Court Judge Pankaj Sharma on May 5, 2026, in a suit filed by Rajdev Steels & Alloys Pvt. Ltd. seeking recovery of Rs 63,60,723 along with contractual interest. The dispute arose from a series of transactions involving the supply of Sponge Iron Lumps and Sponge Iron Fines between May and June 2022.

According to the plaintiff, Bawa Appliances had placed orders for sponge iron materials, following which Rajdev Steels supplied a total of 613.070 metric tonnes of goods. The company stated that invoices amounting to Rs 2.57 crore were raised for the supplies. While the defendant allegedly made partial payments of Rs 1.75 crore and returned certain goods worth Rs 18.16 lakh, a substantial amount remained unpaid despite repeated demands.

The plaintiff further contended that after accounting for returned goods and credit notes, an outstanding balance of Rs 63.60 lakh remained due. The company relied upon tax invoices, e-way bills, ledger accounts, bank statements, GST records, emails, legal notices and electronic records to support its claim.

Bawa Appliances initially appeared before the court and filed a written statement but subsequently stopped participating in the proceedings. The defendant was eventually proceeded against ex parte. In its defence, the company denied liability and claimed that the goods had actually been supplied to another entity, Banke Bihari Steel Pvt. Ltd. It also alleged that the invoices relied upon by the plaintiff were forged and fabricated.

However, the court found that these allegations remained entirely unsupported by evidence. The judgment observed that the defendant neither produced documents to establish that the supplies were made to another entity nor substantiated its claim that the invoices were fabricated.

Rejecting the defence, the court noted that the invoices, e-way bills and ledger entries collectively established the existence of a commercial relationship between the parties. The court observed, “In commercial transactions of this nature, duly proved invoices, supported by transport documents such as e-way bills and corroborated by ledger entries, carry substantial evidentiary value. In absence of rebuttal, such documents are liable to be accepted as proof of supply.”

The court also attached significance to the defendant’s conduct in partially paying the invoices. It held that payments totaling Rs 1.75 crore were reflected in the ledger account and bank records and were not disputed through any contrary evidence. According to the court, the part payments constituted a clear acknowledgment of commercial dealings and liability.

While examining the claim for recovery, the court referred to Sections 31 and 55 of the Sale of Goods Act, 1930. Section 31 imposes an obligation on a buyer to accept and pay for goods in accordance with the contract, while Section 55 allows a seller to sue for the price when a buyer wrongfully neglects or refuses to make payment.

Applying these provisions, the court held that once delivery of goods was established and no valid defence regarding defects or non-supply was proved, the defendant became legally bound to pay the outstanding amount. The court further observed that retention of goods coupled with part payments amounted to acceptance of goods and triggered the statutory obligation to clear the dues.

The defendant had also challenged the maintainability of the suit by arguing that the dispute did not qualify as a commercial dispute under the Commercial Courts Act, 2015. The court rejected this objection and held that the dispute arose from the supply and sale of goods between business entities and therefore squarely fell within the definition of a “commercial dispute” under Section 2(1)(c) of the Commercial Courts Act.

Another defence relating to alleged misjoinder and non-joinder of parties was similarly dismissed due to lack of supporting evidence.

On the issue of interest, the plaintiff sought interest at the rate of 24 percent per annum based on a clause contained in the invoices. The court, however, found the clause to be uncertain because it referred to payment being made within “0 days”. It also considered the claimed rate excessive in the circumstances of the case.

Invoking Section 34 of the Code of Civil Procedure, the court awarded pendente lite interest at the rate of 12 percent per annum on the principal amount from the date of institution of the suit on January 31, 2024, until the date of decree. For the post-decree period, the court awarded future interest at the rate of 9 percent per annum until realization of the decretal amount.

The judgment highlights the evidentiary importance of invoices, e-way bills, ledger accounts and banking records in commercial recovery litigation. It also reiterates that unsupported allegations of forgery or denial of contractual relationships cannot defeat a claim when documentary evidence remains unrebutted. The ruling serves as a reminder that buyers engaged in commercial transactions may face recovery proceedings and interest liability if they retain goods but fail to honour payment obligations.

Consequently, the Commercial Court decreed the suit in favour of Rajdev Steels & Alloys Pvt. Ltd., directing Bawa Appliances to pay Rs 63,60,723 along with interest and litigation costs.

Case Reference: Rajdev Steels & Alloys Pvt. Ltd. v. Bawa Appliances, Commercial Suit No. 04B of 2024