Admission of a document does not concede the truth of its contents; clarification is permissible.

Defendant No. 1 filed an application under Section 151 read with Order VI Rule 17 CPC seeking permission to file an amended affidavit of admission/denial of documents, or clarification of its affidavit dated 17 October 2024.

In that affidavit, the plaint and applications filed by the plaintiff in separate proceedings before the Saket Courts—CS DJ No. 416/2024—had been marked as “accepted” under the heads of correctness and existence of documents. Defendant No. 1 contended that its admission was limited to the documents being true copies of records forming part of the Saket proceedings, and did not extend to admitting the truth of the factual allegations, legal submissions, or prayers contained therein. The plaintiff objected that the original affidavit recorded the documents as admitted under the relevant heads.

1. Whether Defendant No. 1 should be permitted to file a limited amended or clarificatory affidavit of admission/denial concerning the documents at Serial Nos. 5 and 7 of its earlier affidavit?

2. Whether admission of the existence, identity, or receipt of a plaint or application amounts to an admission of the truth of the factual assertions, legal submissions, or prayers contained in that document?

The Court applied Chapter VII Rules 3 and 7A of the Delhi High Court (Original Side) Rules, 2018, read with Order XI Rule 4(2) CPC as applicable to commercial suits, which require a party to separately state whether it admits or denies the correctness of a document’s contents, its existence, execution, issuance or receipt, and custody; where receipt is admitted but contents are denied, the response may be recorded as “Admit (Receipt)”.

The Court held that admission of a document is distinct from admission of the truth of the statements contained in it. Relying on S. Sangeetha v. Tmt. P. Ponni, 2026 SCC OnLine SC 1512, LIC v. Ram Pal Singh Bisen, Narbada Devi Gupta v. Birendra Kumar Jaiswal, and Ramji Dayawala & Sons (P) Ltd. v. Invest Import, the Court reiterated that mere production, marking, or admission of a document does not prove the truth of its contents, which must be established in accordance with law.

The Court found that the statutory scheme governing admission and denial requires the nature and extent of an admission to be identified under separate heads, rather than inferred merely from the use of the word “accepted”. Since the documents in question were pleadings and applications filed in separate proceedings, their admission as records of those proceedings did not, without more, amount to an admission of the truth or legal validity of the assertions contained therein.

Defendant No. 1’s proposed clarification was consistent with its earlier written statement and replies filed in the Saket proceedings and was intended only to remove ambiguity in the earlier affidavit. Applying the principle in Unified Vision Capital, the Court held that permitting such a clarification would not amount to withdrawal of a substantive admission or alteration of the defence, but would properly delineate the documents admitted as records from the contents disputed by Defendant No. 1.

The clarification was directed to remain consistent with the existing pleadings and was not to be treated as withdrawal of any admission, amendment of the written statement, or alteration of the defence. IA No. 31695/2025 was accordingly disposed of. The matter was listed for 14 December 2026 in relation to IA No. 32525/2025.