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Sugandhi (Dead) Through LRs. v. P. Rajkumar Rep. by Power Agent Imamoli

Civil Appeal · 2020 INSC 593Decided 13 Oct 2020
Civil Appeal No. 3427 of 2020
Justice S. Abdul Nazeer · Justice Sanjiv Khanna

Background

In a civil suit for injunction over property, the defendants sought the trial court's leave to produce certain documents they said they had only recently traced, after the plaintiff's evidence had already been led. Both the trial court and the Madras High Court (Madurai Bench) refused to allow the documents in, holding the defendants were not entitled to introduce them at that late stage.

Decision Breakdown

The Supreme Court held that Order 8 Rule 1A(3) CPC gives a court discretion to permit a defendant to produce documents even after the written statement stage, provided good cause is shown, and that this discretion should be exercised liberally in favour of substantial justice rather than narrow technicality, since litigation is ultimately "a journey towards truth." Finding that the defendants had given a credible reason (the documents were only recently located) and that the documents were relevant to a just decision, the Court held the lower courts ought to have granted leave. It set aside both orders and allowed the documents to be produced.

Lesson Learnt

Courts should lean towards allowing relevant evidence to be placed on record when a party shows genuine cause for a delay, rather than shutting out documents on a rigid procedural technicality, especially where no real prejudice is shown to the other side.

Official source (sci.gov.in)View Judgment (PDF)

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