2026 Supreme(AP) 1067

IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI
B.S.Bhanumathi, J.
D.L. Narasimha Rao - Petitioner
Versus
Mangu Annapurna Devi (died) and others - Respondents
Civil Revision Petitions Nos: 3762 and 3763 of 2025
Decided On : 08-04-2026

Courts should avoid rejecting applications for additional evidence on purely mechanical grounds of delay if such evidence is necessary for just adjudication, provided the party can adequately demonstrate the relevance and justification for the delay through a detailed affidavit.

Headnote:(A) Code of Civil Procedure, 1908 - Order VII, Rule 14(3) - Section 151 - Civil Revision Petition - Additional evidence - Application to produce documents after closure of evidence - Trial Court dismissed applications citing significant delay and lack of explanation - Appellate Court held that shutting the doors to evidence on mechanical grounds prevents justice on merits - Court directed petitioner to file a better affidavit detailing relevance of documents and reasons for delay - Orders set aside and matter remanded for fresh consideration. (Paras 12, 19, 20 and 21)

Facts of the case:
The petitioner filed a suit for declaration of title and permanent injunction based on a will. During the arguments stage, the petitioner sought to produce 40 documents (sale deeds and gift deeds) to demonstrate ownership and possession. The trial court dismissed the applications for leave and for reopening evidence due to an 18-year delay and incomplete justification.

Findings of Court:
The High Court held that while the affidavit for production of evidence was inadequate, dismissing the application entirely prevented the court from rendering justice on merits. The Court required the petitioner to file a more detailed affidavit to explain the relevance and delay, while allowing the respondents an opportunity to contest the fresh filing.

Issues: Whether the trial court was justified in dismissing the application for production of documents under Order VII, Rule 14(3) CPC purely on the grounds of delay at the stage of arguments.

Ratio Decidendi: Shutting the doors of leading evidence on mechanical grounds prevents the court from rendering justice on merits; therefore, it is necessary to provide an opportunity to file a better affidavit to justify the production and relevance of additional documents.

Result: Revision Petitions allowed; impugned orders set aside; matter remanded to the trial court.