Introduction to the Jurisdiction Puzzle
Imagine obtaining an arbitral award worth nearly eighty lakh rupees, only to find that the executing court itself is under a cloud of doubt: should the matter lie before an ordinary civil court or a specialised Commercial Court. For litigants and lawyers in Andhra Pradesh, this was not an academic question but a recurring hurdle whenever commercial disputes hovered around shifting monetary thresholds. Conflicting Division Bench rulings in Bellam Balakrishna v. Greenmount Developers and U.V. Satyanarayana v. M/s Shriram City Union Finance Ltd. left the Bar divided on whether the amended “specified value” under the Commercial Courts Act, 2015 truly operated without government notifications.
On 18 May 2026, a Full Bench of the Andhra Pradesh High Court at Amaravati—comprising Justices Cheekati Manavendranath Roy, Ravi Nath Tilhari and Battu Devanand—delivered a landmark common order in a batch of Civil Revision Petitions, led by 3F Industries Limited v. Transparent Technologies Solutions Private Limited, finally settling this controversy. The ruling draws a clear boundary between “specified value” and “pecuniary value”, explains when the 2018 amendment took effect, and identifies which prior precedents did not correctly state the law.
How Thresholds Became Roadblocks
The root of the problem lay in the 2018 Amendment Act (Act 28 of 2018), which reduced the entry ticket for Commercial Courts from disputes above one crore rupees to disputes above three lakh rupees. Section 2(1)(i) of the Commercial Courts Act, 2015 originally defined “specified value” as the value of the subject‑matter determined in accordance with section 12, “which shall not be less than one crore rupees”; this was amended to “which shall not be less than three lakh rupees or such higher value as may be notified by the Central Government.” Simultaneously, a new Section 3(1A) empowered State Governments, in consultation with the High Court, to fix pecuniary value for Commercial Courts by notification, enabling the creation of courts even below District Judge level to cope with increased commercial litigation.
In practice, however, Commercial Courts in Vijayawada and Visakhapatnam continued to entertain only suits above one crore, because earlier administrative proceedings specifying the one‑crore threshold were never withdrawn or replaced. Litigants with disputes above three lakh rupees but below one crore rupees were effectively locked out of the specialised forum the statute had created, as both courts and registry staff treated the pre‑amendment threshold as still controlling. This confusion was compounded when one Division Bench in Bellam Balakrishna held that without a State notification, the amended three‑lakh specified value did not come into operation at all.
Specified Value vs Pecuniary Value: The Court’s Clarification
The Full Bench’s first task was to answer three reference questions: (A) whether the 2018 amendment itself changed the specified value to “not less than three lakh rupees” or merely empowered Governments to do so by notification; (B) from what date the amended specified value became operative; and (C) which of the earlier judgments, U.V. Satyanarayana or Bellam Balakrishna, correctly laid down the law. After tracing the legislative history—from Law Commission reports to the Commercial Courts Ordinance and subsequent Act—the Bench emphasised that “specified value” and “pecuniary value” are conceptually and textually distinct. Section 2(1)(i), in Chapter I, defines “specified value” as the value of the subject‑matter in a commercial dispute determined under section 12; Section 3(1A), in Chapter II, deals with pecuniary limits of different Commercial Courts when presided over by officers of various cadres.
The Court held that specified value determines whether a dispute qualifies to be tried by a Commercial Court at all; pecuniary value relates to the monetary ceiling or floor of a particular Commercial Court within the hierarchy (e.g., District Judge‑level or below). Amending Section 2(1)(i) by deleting “not less than one crore rupees” and substituting “not less than three lakh rupees” therefore, by itself, reduced the specified value threshold, without any need for a further Central Government notification to make the amendment operative. Notifications become relevant only if and when the Central Government wishes to raise the specified value beyond three lakh rupees, or the State Government wishes to confer jurisdiction on courts below the District Judge by fixing their pecuniary limits under Section 3(1A).
The 2026 Full Bench Verdict: Clearing the Confusion
On Question A, the Full Bench answered that Sections 2(1)(i) and 3(1A) are “two distinct and separate provisions” and “not one and the same,” and that the 2018 amendment itself fixed the specified value at “not less than three lakh rupees.” No separate Central Government notification is required for disputes above three lakh rupees to qualify as commercial disputes triable by Commercial Courts; notifications are only needed to fix a higher threshold in exercise of delegated legislative power.Judgment.pdf
On Question B, the Court held that the amendment to Section 2(1)(i) became operative from the date of amendment, i.e. 3 May 2018, and applies prospectively to transactions occurring on or after that date. Section 19 of the Amendment Act makes clear that the new specified value does not retrospectively affect transactions prior to 3 May 2018, so pre‑amendment disputes still have to satisfy the earlier one‑crore threshold to qualify as “commercial disputes of a specified value.” As regards the State Government’s power under Section 3(1A), the Bench reiterated that this concerns only pecuniary value for different cadres of Commercial Courts, and has “absolutely nothing to do with” specified value under Section 2(1)(i).
On Question C, the Full Bench expressly held that Bellam Balakrishna did not correctly state the law. The earlier Bench had treated the amended specified value in Section 2(1)(i) as dependent on a State notification, but the Full Bench clarified that Section 2(1)(i) does not deal with pecuniary value at all and that specified value flows directly from the statute once amended. The Court also examined U.V. Satyanarayana, noting that the arbitration award there was for forty‑five lakh rupees and arose from transactions prior to 3 May 2018—below the then specified value of one crore rupees—so that dispute never qualified to go to a Commercial Court. To that extent, U.V. Satyanarayana failed to appreciate the specified‑value requirement, and the Full Bench clarified the correct legal position.
Beyond answering the reference, the Bench addressed practical implementation failures in Andhra Pradesh. It recorded that Commercial Courts in Vijayawada and Visakhapatnam were still receiving only suits above one crore rupees and directed that fresh proceedings be issued, specifying the amended three‑lakh threshold and ensuring that all commercial disputes above three lakh rupees—up to one crore—are received and tried in the Commercial Courts from 3 May 2018 onwards. The Court further recommended that the State Government, in consultation with the High Court, promptly operationalise previously approved plans to convert Fast Track Courts into Commercial Courts in the cadre of Senior Civil Judge, and issue notifications under Section 3(1A) fixing their pecuniary jurisdiction between three lakh and fifty lakh rupees.
References & Verified Sources:
- Judgment: 3F Industries Limited v. Transparent Technologies Solutions Private Limited and batch, Civil Revision Petition Nos. 1847/2024, 1172/2022, 1685, 1686, 1688 and 1689 of 2024, Full Bench of the High Court of Andhra Pradesh at Amaravati, common order dated 18 May 2026.
- Prior Precedents Discussed: M/s Obulapuram Mining Company Pvt. Ltd. v. R.K. Mining Private Limited (CRP No.2183/2022, decided 12‑09‑2023); Bellam Balakrishna v. Greenmount Developers (CRP No.1749/2023, decided 28‑08‑2023); U.V. Satyanarayana v. M/s Shriram City Union Finance Ltd. (CRP No.740/2024, decided 04‑07‑2024); M/s Janset Labs Pvt. Ltd. v. Agilent Technologies India Pvt. Ltd. (CRP No.1932/2025, decided 22‑09‑2025).
- Statutes & Key Provisions: Commercial Courts Act, 2015—Sections 2(1)(c), 2(1)(i), 2(2), 3(1), 3(1A), 3(3), 10(3), 12 and 15(2); Commercial Courts, Commercial Division and Commercial Appellate Division of High Courts (Amendment) Act, 2018 (Act 28 of 2018), including Sections 4(II), 6(b) and 19.
- Related Law: Andhra Pradesh Civil Courts Act, 1972—Sections 2, 10, 12 and 16 (pecuniary jurisdiction of ordinary civil courts); Article 13(3)(a) of the Constitution of India (definition of “law” including delegated legislation by notification).