Order VIII Rule 1-A(3) — Reception of Documents — Relevancy of Evidence Documents sought to be received under Order VIII Rule 1-A(3) CPC must have direct relevance to the matter in issue. Irrelevant documents, even if genuine, cannot be received merely because they are executed by the party.

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Civil Procedure Code, 1908 — Order VIII Rule 1-A(3) — Reception of Documents — Relevancy of Evidence

Documents sought to be received under Order VIII Rule 1-A(3) CPC must have direct relevance to the matter in issue. Irrelevant documents, even if genuine, cannot be received merely because they are executed by the party.

Evidence — Suit on Promissory Note — Plea of Forgery — Comparative Signatures

In a suit based on a promissory note, where the defence is that the signature on the promissory note is forged, a document executed on a different occasion and for a different transaction, even if signed by the defendant, does not become relevant per se unless it directly assists in adjudicating the disputed signature.

Supervisory Jurisdiction — Article 227 — Limited Interference

Interference under Article 227 of the Constitution is not warranted where the trial Court has exercised its discretion judiciously and rejected production of documents on the ground of irrelevance.

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ANALYSIS OF FACTS AND LAW

Facts

• The respondent filed O.S. No.147 of 2020 for recovery of money based on a promissory note.

• The petitioner/defendant pleaded forgery, contending that:

  • He does not sign in Telugu;

  • He signs only in English.

• To support this plea, the defendant filed I.A. No.661 of 2025 under Order VIII Rule 1-A(3) CPC, seeking to receive a registered settlement deed, allegedly signed by him in English.

• The trial Court dismissed the application, holding that the document was irrelevant.

• The defendant challenged the said order under Article 227.

Issue

Whether a registered settlement deed executed by the defendant in English is relevant and admissible to decide the plea of forgery in a suit on a promissory note allegedly signed in Telugu.

Findings

1. Relevance is the Governing Test
   The High Court held that admissibility under Order VIII Rule 1-A(3) CPC is not automatic; relevance to the controversy is essential.

2. Nature of Dispute is Narrow
   The controversy is confined to the genuineness of the signature on the promissory note.

3. Collateral Documents Not Automatically Relevant
   A settlement deed executed on a different occasion, relating to a different transaction, does not assist in deciding whether the defendant signed the promissory note in question.

4. No Jurisdictional Error
   The trial Court correctly exercised its discretion. The order did not suffer from perversity, illegality, or jurisdictional error.

5. Article 227 Cannot Be Used as an Appeal
   The High Court reiterated that supervisory jurisdiction cannot be invoked to re-appreciate discretionary procedural orders of the trial Court.

Result

The Civil Revision Petition was dismissed, affirming the trial Court’s refusal to receive the document.

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RATIO DECIDENDI

A document sought to be received under Order VIII Rule 1-A(3) CPC must be directly relevant to the issue in dispute; in a suit on a promissory note alleging forgery of signature, a registered settlement deed executed by the defendant on a different occasion does not become admissible merely to show the language of his usual signature, and refusal to receive such a document does not warrant interference under Article 227.