Procedure is the Handmaid of Justice: Delhi High Court Allows Key Document in Commercial Dispute but Dismisses Affidavit of Admission/Denial at Advanced Trial Stage
In a significant judgment, the Delhi High Court, presided over by Hon’ble Ms. Justice Shalinder Kaur, allowed the introduction of a critical letter dated 08.07.2022 in the ongoing legal battle between Sudhir Power Project Ltd. and Prime Meiden Pvt. Ltd., but rejected the plea to include an affidavit of admission/denial at this advanced stage of the trial.
Legal Point:
The case hinged on the application of Order VIII Rule 1A(3) of the Code of Civil Procedure, 1908 (CPC), focusing on the admissibility of additional documents submitted at a later stage in a trial. The key legal issue was balancing procedural fairness with the pursuit of substantial justice.
Background and Issues:
The dispute originated from the respondent’s failure to adhere to terms in purchase orders, leading to liquidated damages imposed on the petitioner by their end customer, HSIIDC. The trial court had previously rejected the petitioner’s request to include a letter and affidavit, both pivotal to the petitioner’s defense.
Court’s Assessment:
Justice Shalinder Kaur meticulously analyzed the submissions and circumstances surrounding the delayed submission of the documents. Relying on precedents, the court observed, “procedure is the handmaid of justice,” emphasizing the importance of enabling courts to uncover the truth and ensure justice.
The Court found the letter, issued after the filing of the written statement, to be relevant and the delay in its submission justifiable. However, the Court held that allowing the affidavit at this stage would not serve any purpose and might prolong the trial, which is already at the evidence stage.
Decision:
The Court permitted the inclusion of the letter, recognizing its significance in the dispute. However, it declined to admit the affidavit, citing the need to avoid procedural delays and the advanced stage of the trial.
Date of Decision: March 11, 2024
Sudhir Power Project Ltd. vs Prime Meiden Pvt. Ltd.
