Appellate Court shall not re-appreciate evidence in commercial suits absent perversity or arbitrariness in trial court findings.

The Respondent (Plaintiff) filed a commercial suit for recovery of Rs. 12,22,437/- plus 18% interest per annum against the Appellant (Defendant)

In his written statement, the Appellant admitted an outstanding liability of Rs. 5,14,844.88

Consequently, the Trial Court passed a partial decree for the admitted amount under Order XII Rule 6 of the CPC on May 24, 2025

For the remaining contested amount of Rs. 7,07,592.92, the Trial Court conducted a trial where the Appellant claimed to have made cash payments and payments to nominees, but failed to provide evidence for the same

The Trial Court eventually decreed the suit in full on September 3, 2025. The Appellant challenged the decree with a 64-day delay

1. Whether the delay in filing the appeal should be condoned and whether the impugned judgment warrants interference on merits

2. Whether a decree based on an admission in the written statement and subsequent failure to prove disputed payments in trial is sustainable

3. Whether an appellate court in commercial suits is required to re-appreciate all evidence in the absence of perversity

The Court applied Order XII Rule 6 of the Code of Civil Procedure (CPC) regarding judgments on admissions

It emphasized the legislative intent of the Commercial Courts Act for the "expeditious disposal" of suits

The Court also applied the principle of appellate review, stating that re-appreciation of evidence is not required unless there is "perversity or arbitrariness"

The Court found that the Appellant’s delay in filing the appeal was not sufficiently explained

On the merits, the Court noted that the supply of goods and the buyer-seller relationship were admitted

During cross-examination, the Appellant admitted that the invoices were correct and that he had previously acknowledged the full statement of account via WhatsApp

The Court reasoned that since the Appellant failed to lead evidence to prove the alleged cash payments or payments to third-party nominees, the Trial Court’s findings were grounded in the facts and evidence on record

The Court rejected the argument that the Appellant was "ill-advised" in drafting his pleadings, noting that such a claim does not constitute a valid ground for reversal

The High Court dismissed the appeal and all pending applications

The Court underscored that in commercial appeals, the court need not undertake a "deep-dive" into evidence if the trial court’s view is plausible and free from perversity

The next hearing date was cancelled