Courts may permit witnesses to produce previously undisclosed relevant documents where no prejudice is caused.

The petitioner instituted a commercial suit seeking, inter alia, recovery of ₹89,32,221.10, alleging that the respondent bank had charged interest at a rate higher than agreed during 2018–2021.

The bank’s written statement denied the allegation and attributed changes in interest rates to the petitioner’s credit ratings and bank norms.

After the petitioner’s evidence concluded, the bank applied to summon a witness to produce the applicable interest-rate tables, the petitioner’s credit-rating details, and records concerning a ₹31 lakh deduction.

The Trial Court allowed the application, finding the documents relevant and noting that the loan had been sanctioned through a different processing centre; the petitioner challenged that order under Article 227.

1. Whether the Trial Court was justified in allowing the bank’s application under Order XVI Rule 1 read with Section 151 of the CPC to summon a witness to produce the documents in question.

2. Whether allowing production of those documents at the defendant’s evidence stage warranted interference under Article 227, given the petitioner’s objections concerning non-disclosure and prejudice.

Order XVI Rules 1 and 1-A of the CPC permit a party to summon a witness to give evidence or produce documents; documents produced through such a witness may be taken on record even if the calling party did not file copies earlier (Ashok Sharma v. Ram Adhar Sharma).

The amended Order XI CPC governing commercial disputes allows belated document disclosure for reasonable cause, a standard less rigorous than “sufficient cause” (Darrameks Hotels & Developers (P) Ltd. v. Brilltech Engineers (P) Ltd.).

Procedural rules should not obstruct substantial justice where the violation does not seriously prejudice the opposing party (Sugandhi v. P. Rajkumar).

Under Article 227, the High Court does not sit in appeal and ordinarily will not interfere absent perversity or patent illegality.

Decisions of another High Court are persuasive, not binding (Valliamma Champaka Pillai v. Sivathanu Pilla).

The documents went directly to the dispute over the interest rate, credit ratings, and deduction from the petitioner’s account, and the bank’s written statement had put those matters in issue.

The witness had already been named in the bank’s witness list, and the application was made shortly after the list was filed and DW-1 was discharged.

The Court accepted that obtaining records from a public-sector bank’s relevant processing centre could account for the short delay; it also noted that the petitioner could test the documents’ authenticity and veracity during evidence.

In these circumstances, the Trial Court’s decision to permit production caused no grave prejudice and disclosed no basis for Article 227 interference.

It dismissed the petition and pending applications, vacated the interim stay, and clarified that it had not considered the merits of the underlying suit.