Absence of relevance and lack of due diligence justify dismissal of late-stage applications to receive documents.

The petitioners (plaintiffs) filed a suit in 1998 for partition and separate possession, claiming the suit properties were ancestral.

The contesting defendants (Respondents 4, 6, 7, and 8-11) argued that portions of the suit property were self-acquired or purchased through valid sale deeds executed in 1976, 1979, and 1982, and that the suit was barred by limitation.

Following the closure of evidence on April 12, 2022, and while the matter was posted for arguments, the plaintiffs filed three Interlocutory Applications (I.A. Nos. 7, 8, and 9 of 2022) to reopen evidence, recall P.W.1, and receive twelve additional documents.

The Trial Court dismissed these applications on November 10, 2022, citing a lack of relevance of the documents and the 24-year pendency of the suit.

The plaintiffs challenged these dismissals under Article 227 of the Constitution of India.

Whether the Trial Court committed a jurisdictional error or illegality in dismissing the applications to reopen evidence and receive additional documents at the stage of final arguments.

Whether the documents sought to be produced by the plaintiffs were relevant and necessary for the adjudication of the partition suit.

The Court exercised its supervisory jurisdiction under Article 227 of the Constitution of India.

It applied the procedural principles governing the production of documents post-trial as contemplated under the Code of Civil Procedure (CPC), specifically regarding the requirement for parties to produce evidence before the closure of their side and the necessity of demonstrating the relevance of "newly discovered" evidence.

The Court also considered the Hindu Succession (Tamil Nadu Amendment) Act (Act 1 of 1990) and Section 6 of the Hindu Succession Act, 1956, regarding the rights of daughters as coparceners in ancestral property.

The Court conducted a document-by-document review of the twelve items the plaintiffs sought to introduce.

It found that the family cards, disability certificates, and newspaper publications were irrelevant to the title or partition dispute.

Regarding the study certificate of the second defendant (Doc No. 5), the Court noted that since the contesting defendants claimed purchase of the property prior to the 1990 Amendment, the exact date of marriage was immaterial to the specific defense of third-party ownership.

The Court further observed that the plaintiffs failed to provide any valid reason for the non-production of these documents during the 24 years the suit was pending.

It determined that the documents were either already on record, related to non-suit properties, or lacked probative value for the plaintiffs' case.

Consequently, the Court found the applications were a dilatory tactic to delay a trial that had already lasted over two decades.

The Court held that there was no irregularity or illegality in the Trial Court's conclusion that the applications were intended to drag on proceedings and that the documents were not relevant to the issues at hand.

The Trial Court was directed to dispose of the 1998 suit expeditiously in light of its extreme age.