Reliance Industries Limited v. NTPC Limited
Background
NTPC sued Reliance Industries Limited (RIL) in 2006 for specific performance of a Letter of Intent under which RIL was to supply a huge quantity of natural gas to NTPC's power plants over 17 years, alleging RIL never honoured the agreed terms. Over roughly two decades, RIL repeatedly used procedural applications - discovery requests, chamber summonses, appeals, and special leave petitions - which the Bombay High Court and even the Supreme Court itself (in a 2019 ruling in the same dispute) found to be attempts to delay the trial and bring inadmissible "internal" documents and correspondence into evidence indirectly through oral testimony. The immediate dispute before the Court was whether the Bombay High Court, in a 2024 order, had correctly applied the Supreme Court's 2019 ruling when deciding which portions of a witness's evidence affidavits should be redacted as inadmissible internal communications.
Decision Breakdown
The Supreme Court examined the High Court's paragraph-by-paragraph redaction exercise in detail and found it faithfully applied the earlier Supreme Court ruling - redacting genuinely internal communications while retaining portions reflecting the witness's own perceptions or correspondence actually exchanged between the parties. The Court upheld the High Court's order in full, finding no error, and used the occasion to strongly criticize RIL for having obstructed and prolonged the litigation for nearly twenty years through what it called an almost unlimited "power to litigate." The appeal was dismissed with costs of Rs. 10 lakhs payable by RIL, and the Court directed the trial court to conclude the long-pending suit expeditiously.
Lesson Learnt
Courts can and will penalize a well-resourced litigant for using repeated procedural applications and appeals to delay a case for decades; a party's own internal notes and emails, not shared with the other side, generally cannot be brought into evidence indirectly through a witness's oral testimony once they have already been excluded as irrelevant documents.