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Informative

Delhi High Court on Filing of Additional Documents: Application Cannot Be Allowed After Inordinate Delay

Update / Judgement Date

07 Dec 2025

Source

WCP News Bulletin

Author

Sakshi Bhardwaj — WCP Legal Desk

Reading Time

2 min read

Civil LawOther Legal Matters
Delhi High Court on Filing of Additional Documents: Application Cannot Be Allowed After Inordinate Delay
WCP News Bulletin
Headnote:

The Delhi High Court dismissed a petition challenging the rejection of an application filed under Order VIII Rule 1A CPC seeking to place additional documents on record. The Court held that inordinate delay of nearly seven years without any explanation and failure to disclose the nature and relevance of the documents amounts to abuse of process. The Court emphasised that permitting such documents at the stage of defence evidence would seriously prejudice the plaintiff.


Background:

• The respondent/plaintiff filed a money recovery suit in May 2016.

• Written statement was filed by the defendants in June 2017 and issues were framed on 11.10.2017.

• The plaintiff concluded its evidence on 05.06.2023 and the matter was listed for defence evidence.

• After seeking adjournment, the defendants filed an application under Order VIII Rule 1A CPC to place additional documents on record.

• The Trial Court dismissed the application by order dated 18.07.2024.


Court’s Observations:

• The application did not disclose the nature or relevance of the documents sought to be produced.

• No explanation was offered for the delay of almost seven years.

• The plea of office shifting was neither pleaded before the Trial Court nor substantiated.

• The documents were admittedly in the possession of the defendants.

• Allowing the documents at such a belated stage would prejudice the plaintiff who had already closed evidence.


Held:

• No infirmity was found in the impugned order of the Trial Court.

• The petition was found to be frivolous and devoid of merit.

• The petition and connected applications were dismissed with costs of ₹10,000/- payable to DHCLSC within one week.


Legal Provisions Discussed:

• Order VIII Rule 1A, Code of Civil Procedure, 1908

• Principles governing production of documents and diligence

Case: M/s Alpro Industries & Ors. v. M/s Indo Alusys Industries Ltd.

Court: High Court of Delhi at New Delhi

Coram: Justice Girish Kathpalia

Date of Decision: 02 December 2025

Case No.: CM(M) 2332/2025 with CM Appl. 75607/2025, 75608/2025 & 75606/2025