Delay in filing additional documents is no bar to their admission if necessary for adjudication.

The respondent (complainant) filed a complaint in 2014 under Section 138 of the Negotiable Instruments Act, 1881, alleging the dishonour of multiple cheques issued by the petitioner.

In 2023, during the chief examination of the complainant’s witness, the respondent moved an application to bring additional documents (registration certificate, partnership deed, and contracts) on record.

The trial court allowed this application on 25/07/2023.

The petitioner challenged this order before the High Court, contending that the nine-year delay was unjustified, the order was non-speaking, and it allowed the complainant to fill lacunae in their case.

1. Whether the trial court's interlocutory order permitting additional documents at a belated stage warrants interference under the inherent jurisdiction of the High Court.

2. Whether the lack of detailed reasoning in a procedural trial court order constitutes a patent illegality.

Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) [formerly Section 482 CrPC], which grants inherent powers to prevent abuse of the process of law or secure the ends of justice.

Procedural rules are intended to advance the cause of justice rather than thwart it.

Inherent powers should be exercised sparingly and not as a substitute for appellate or revisional jurisdiction, especially against interlocutory orders.

The court reasoned that although there was a significant delay of nine years in filing the application, delay alone is not sufficient grounds for rejection if the documents are relevant for an effective adjudication of the dispute.

The court found no prejudice to the petitioner because the trial was still at the stage of evidence, allowing the petitioner ample opportunity to cross-examine witnesses regarding the new documents.

Addressing the "non-speaking" argument, the court held that in matters of procedural discretion, elaborate reasoning is not mandatory if the order does not finally determine the rights of the parties.

The court noted that interfering at this stage would result in "fragmenting the trial" and causing further delay in a summary proceeding intended for expeditious disposal.

The petitioner remains at liberty to challenge the admissibility, relevancy, and evidentiary value of the documents during the trial, and the trial court must consider such objections strictly in accordance with law.