To ensure compliance with Order II Rule 2 while filing a civil suit, lawyers must follow a systematic procedure verifying that the cause of action is complete, consistent, and unified. Before drafting the plaint, they should carefully identify every material fact giving rise to the legal right and correlate each to the remedies available under substantive law. Advocates must then confirm that all reliefs arising from the same cause of action—whether declaratory, mandatory, or compensatory—are included in one suit or that leave of court is sought under Rule 2(3) for deferred claims. As emphasized by the Supreme Court in Cuddalore Powergen Corporation Ltd. v. Chemplast Cuddalore Vinyls Ltd. (2025), a cause of action must be established through a factual bundle sufficient to justify one comprehensive claim. Drafting best practices include maintaining a case checklist that cross‑references facts, reliefs, and defendants, reviewing earlier claims to avoid overlap, and conducting pre‑trial verification to ensure that each pleaded fact supports at least one relief. This disciplined approach, supported by court guidance in Gurbux Singh v. Bhooralal and LIC of India v. Sanjeev Builders Pvt. Ltd., helps prevent inadvertent claim omission, procedural bar, or rejection under Order VII Rule 11 for non‑disclosure of cause of action.
