Order VIII Rule 14(3) CPC – Belated production of documents – Scope (Paras 5, 9–10) Though additional documents may be permitted at a later stage of trial, such permission is not automatic. The party must establish relevance, admissibility and necessity. Where documents are neither relevant to the issues nor legally admissible, permission to mark them can be refused even if trial is pending.

advocatemmmohan

Civil Procedure – Order VIII Rule 14(3) CPC – Belated production of documents – Scope
(Paras 5, 9–10)
Though additional documents may be permitted at a later stage of trial, such permission is not automatic. The party must establish relevance, admissibility and necessity. Where documents are neither relevant to the issues nor legally admissible, permission to mark them can be refused even if trial is pending.

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Evidence – Relevance – Documents not connected to issues – Rejection justified
(Para 9)
In a suit for permanent injunction, documents relating to alleged quarrels or criminal incidents between parties, having no direct nexus with the civil dispute, are not relevant for adjudication and need not be received in evidence.

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Evidence – FIR – Evidentiary value – When declared false
(Paras 4, 9)
Where an FIR is investigated and a final report is filed declaring it as false, and such report is accepted by the competent criminal court, the FIR loses probative value and cannot be relied upon in civil proceedings.

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Evidence – Admissibility – Documents declared false – Inadmissible
(Para 9)
Documents which have been found to be false by the competent authority and accepted as such by a court of law are neither valid nor admissible for determination of civil rights.

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Civil Trial – Stage of proceedings – Closure stage – Additional evidence
(Para 9)
Where trial has reached closure stage and evidence of one side is completed, belated attempt to introduce additional documents, without sufficient justification and relevance, can be legitimately rejected.

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Distinction – Valid documents vs false documents – Belated filing
(Para 10)
Judicial precedents permitting reception of documents at a belated stage apply only to valid and legally admissible documents. Such principles do not extend to documents which are inherently unreliable or declared false.

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Supervisory jurisdiction – Article 227 – Interference – Limited scope
(Paras 9–10)
Where the trial court has exercised discretion judiciously in rejecting irrelevant and inadmissible documents, such order does not warrant interference under Article 227 of the Constitution.

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RESULT

Rejection of application to mark certified FIR and CD upheld; Civil Revision Petition dismissed.
(Paras 9–11)

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CASE REFERENCE

CRP No.2328 of 2025

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CORE RATIO

Para 9

Documents which are irrelevant to the issues and have already been declared false in criminal proceedings are inadmissible in civil trial, and refusal to receive such evidence at a belated stage calls for no interference.