Delhi High Court Upholds Rejection of SBI's Application to Introduce Additional Documents in Decade-Old Suit

Court dismisses State Bank of India's plea to submit documents during final arguments, citing lack of satisfactory explanation for delay.

In a recent decision, the Delhi High Court upheld the trial court's rejection of an application filed by the State Bank of India (SBI) seeking to introduce additional documents in a decade-old civil suit. The application, filed under Order VIII Rule 1A(3) of the Civil Procedure Code, 1908, was dismissed on the grounds that SBI failed to provide a satisfactory explanation for the delay and appeared to be attempting to fill gaps exposed during the final arguments.

Justice Girish Kathpalia presided over the case, where SBI, represented by Advocate Ms. Jaya Tomar, sought to challenge the trial court's order dated October 18, 2025. The bank argued that the documents were misplaced due to the relocation of its Regional Business Office from Meerut to Muzaffar Nagar and surfaced during the final arguments. However, the court found this explanation vague and insufficient, particularly given the bank's extensive resources and legal infrastructure.

The court highlighted that SBI, as a nationalized bank, should have maintained better oversight of its documents. The judge emphasized that the bank's lack of vigilance and the timing of its application suggested an attempt to rectify shortcomings identified by the opposition during the final arguments.

The judgment also referenced a Supreme Court ruling in Sugandhi (Dead) by LRs v. P.Rajkumar, which noted that there is no one-size-fits-all approach to granting such applications. The court found SBI's situation distinct from the Sugandhi case, where documents were filed before the commencement of evidence and accompanied by a credible explanation.

Despite SBI's argument that the additional documents were relevant, the court noted that the respondent had contested their relevance in their reply. Furthermore, it was highlighted that SBI's evidence was closed voluntarily by its counsel, and no attempts were made to delay proceedings for additional evidence.

Allowing SBI's application, the court observed, would effectively restart the trial, burdening the respondent and undermining judicial efficiency. Consequently, the court upheld the trial court's decision, dismissing SBI's petition and any pending applications.

This ruling underscores the importance of timely and diligent handling of evidence in legal proceedings, particularly for institutional litigants with substantial resources at their disposal.

Bottom Line:

Application under Order VIII Rule 1A(3) CPC filed after part final arguments to introduce additional documents cannot be allowed when there is no satisfactory explanation for delay and the attempt appears to be to fill in lacunae pointed out during arguments.

Statutory provision(s): Civil Procedure Code, 1908, Order VIII Rule 1A(3)

State Bank of India v. Shri S C. Goel, (Delhi) : Law Finder Doc Id # 2812892