Advocates should approach the drafting of reliefs with a comprehensive understanding of Order II Rule 2(3) and Order VII Rules 7 and 8 of the Civil Procedure Code to ensure that every relief arising from a single cause of action is included in the suit. The relief clause should explicitly mention both primary and alternative remedies—such as damages, injunctions, or specific performance—relating to the same transaction, backed by clear factual linkage to the cause of action. While drafting, lawyers should cross‑verify that all factual assertions in the plaint correspond to some form of requested relief to comply with the “whole claim requirement.” Courts have emphasized that omission or deliberate relinquishment of any part of such relief, without obtaining leave under Order II Rule 2(3), permanently bars the plaintiff from filing a subsequent suit for the omitted part, as reaffirmed in R. Kandaswamy v. Pacha Goundar (2022) and LIC of India v. Sanjeev Builders Pvt. Ltd. (2022). Therefore, advocates must scrutinize factual interconnections, seek leave where appropriate, and ensure every possible relief is articulated to preserve the client’s full legal entitlement.
