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2026 Supreme(Online)(Tel) 18406

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
K. Sarath, J
T. Venkat Rao – Appellant
Versus
Bollepally Venkanna – Respondent
CIVIL REVISION PETITION Nos.7 and 76 of 2026



Advocates:
For the Appellants/Petitioners: Papaiah Peddakula
For the Respondents: Ashvini Kumar

A party cannot be permitted to produce additional documents at a belated stage without showing 'sufficient cause' for their non-production during the initial pleadings, especially when the documents are not supported by the pleadings and the party has previously attempted similar relief without success.

Headnote:The petitioner challenged the trial court’s dismissal of applications filed under O.VIII R.1 and O.XVIII R.17 of the CPC, which sought to recall a witness and admit additional documents in an ongoing civil suit. These documents were allegedly withheld due to their prior mortgage with a private financier, a claim unsupported by evidence. In determining the validity of these applications, the court framed the issue of whether a party may introduce additional documents at a belated stage while suppressing prior failed attempts for the same relief. The court reasoned that the failure to establish 'sufficient cause' for the non-production of documents alongside pleadings, combined with the lack of underlying pleadings supporting such evidence, necessitated the denial of the applications. The Civil Revision Petitions were dismissed as they were found to be devoid of merits.

Table of Content
1. procedural background and context of the revision petitions. (Para 1 , 2 , 3 , 4 , 5)
2. analysis of the necessity of pleadings to support newly introduced documents. (Para 6 , 8 , 9 , 13 , 14)
3. court's discretion to reject applications lacking merit and 'sufficient cause'. (Para 11 , 12 , 15 , 16)

COMMON ORDER:

Since both the Civil Revision Petitions arise out of one and the same suit in O.S.No.137 of 2015 on the file of I Additional District and Sessions Judge, Bhongir, Yadadri-Bhongir District, they are heard together and being disposed of by this common order at the stage of admission itself.

2. Heard Sri Papaiah Peddakula, learned counsel for the petitioner/defendant and Sri Ashvini Kumar, learned counsel for the respondent/plaintiff and perused the record.

3. C.R.P.Nos.7 and 76 of 2026 are filed against the orders passed in I.A.No.60 of 2025 in O.S.No.137 of 2015 and I.A.No.363 of 2025 in O.S.No.137 of 2015 on the file of the I Additional District and Sessions Judge, Bhongir, Yadadri Bhongir District dated 28.10.2025.

4. The petitioner/defendant filed I.A.No.60 of 2025 in O.S.No.137 of 2015 under Order XVIII Rule 17 CPC read with Section 151 CPC to recall the evidence of D.W.1 for the purpose of marking the documents and to lead evidence in respect of the said documents and also filed I.A.No.363 of 2025 in O.S.No.137 of 2015 under Order VIII Rule 1 read with Section 151 CPC to receive certain documents for disposal of the suit and the said petitions were dismissed on 28.10.2025.

5. Learned Counsel for the petitioner/defendant submits that the respondent/plaintiff filed suit in O.S.No.137 of 2015 for declaration of title, injunction and cancellation of registered document No.6068/2014 dated 13.06.2014. In the said suit, plaintiff’s evidence was closed, the petitioner herein was examined himself as D.W.1 and the matter was posted for his further evidence. At this stage, the petitioner-defendant noticed that he has not filed the original sale deed, its link documents, ROR pattadar passbook and title deed vide No.1129214, patta No.1131 and a true copy of pahani for the year 2014-15, which are important and crucial documents in support of his case and therefore, he filed these petitions to recall D.W.1 for the purpose of marking of those documents as exhibits on his behalf and the said petitions were dismissed.

6. Learned Counsel for the petitioner/defendant further submits that the trial Court failed to appreciate the fact that the original registered sale deed, mutation proceedings, pahani and pattadar passbook and title deed are genuine and relevant documents to establish title, possession and revenue recognition of the suit schedule property in favour the petitioner/defendant. The trial Court failed to consider that merely because the plaintiff’s evidence was closed, the petitions to recall D.W.1 and to receive the documents cannot be rejected as those documents are relevant and necessary for proper adjudication of the matter. He further submits that the trial Court failed to appreciate the fact that the respondent/plaintiff pleaded that he has executed the registered sale deed and also handed over the pattadar passbook and title deed and the said sale deed was also implemented in the revenue records. He further submits that the Trial Court failed to appreciate that for recalling the evidence of D.W.1 and to receive the documents by allowing the petitions would not cause any prejudice to the respondent-plaintiff and as the suit is at the stage of defendant’s evidence, he requested to allow the Civil Revision Petitions by setting aside the impugned orders.

7. Learned Counsel for the petitioner has relied on the following Judgment;

1. Sugandhi (dead) by Lrs vs. P. Rajkumar rep. by his Power Agent Imam Oli1(2020) 10 SCC 706

8. Learned Counsel for the respondent/plaintiff submits that the petitioner/defendant has not filed the said documents intentionally with a view to drag on the matter and after adducing

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