Is a suit for bare injunction maintainable despite denial of title where the question of title is simple and not complicated?

Paragraph 25The question of whether the Suit being one for bare injunction is maintainable in the absence of the relief of declaration despite the defendant's denial of title, gains significance at this juncture. The learned Senior Counsel appearing for the appellant rightly placed reliance on Syed Dhasthakeer's Case [cited supra], wherein a learned Single Judge of this Court has held thus: "11. A comparative study of the relevent provisions of the Specific Relief Act, 1963 and the Tamil Nadu Court Fees and Suits Valuation Act, 1955 will show that there cannot be a blanket principle that when the title is denied a suit for bare injunction without a prayer for declaration shall be dismissed as not maintainable. Even the judgment relied on behalf of the Appellant does not say that a Suit for bare injunction, in case of denial of title of the Plaintiff by the Defendant, is not maintainable. On the other hand, the Hon'ble Supreme Court in Anathula Sudhakar v. P. Buchi Reddy (Dead) by LRs., 2008 (6) CTC 237 (SC), has held in clear terms that when the title of the Plaintiff in a Suit for bare injunction is disputed, the Court can go into the matter. After categorising the cases, the Apex Court held that if the issue regarding the title is simple and not complicated, the same can be decided in the Suit for injunction itself and on the other hand, if the Court is of the view that the issue is so complicated and it cannot be conveniently dealt with in the Suit for injunction and a detailed and elaborate enquiry is needed, then the Court could relegate the parties to a regular Suit for declaration to establish title and consequential relief of injunction. It must be noted that even in the said case dealt with by the Apex Court, the Apex Court, after holding that the question of title involved in the said case was not simple one and it was complicated requiring detailed and elaborate enquiry, the Apex Court allowed the Appeal and gave leave to the Plaintiff therein to file a Suit for declaration and consequential reliefs. Only as a rule of convenience for the Court, the prayer for bare injunction in respect of immovable property are to be denied relegating the parties making the claim to seek declaration of title and injunction as a consequential relief."