Pendency of an application since a prior year is not a valid legal ground for its summary rejection.

The petitioner, who is the plaintiff in Special Civil Suit No. 33 of 2020 pending before the Additional Senior Civil Judge, Surat, filed multiple applications (Exhibits 21, 22, and 23) to bring the legal heirs of the deceased defendant No. 2 onto the record

Due to a delay in these filings, the petitioner also sought to condone the delay and set aside the abatement of the suit

While these applications were still at the stage of serving notice to the legal heirs, the Trial Court rejected them because they had been pending since 2022

The petitioner challenged these rejections before the High Court of Gujarat under Article 227 of the Constitution of India

1. Whether the Trial Court’s rejection of applications solely on the grounds of their duration of pendency, without a speaking order or merit-based adjudication, constitutes a valid exercise of judicial discretion

2. Whether the High Court should exercise its supervisory jurisdiction under Article 227 to set aside an arbitrary procedural order

Article 227 of the Constitution of India, which grants High Courts supervisory jurisdiction over subordinate courts to ensure they act within the bounds of their authority and follow the principles of natural justice

The court also relied on the principle that judicial orders must be "speaking orders"—meaning they must contain reasoned justifications—and that mere procedural pendency is not a legal ground for dismissing applications for bringing legal heirs onto the record

The High Court observed that the Trial Court failed to appreciate the actual status of the applications, which were still at the notice-serving stage

The Court found the Trial Court’s dismissal to be "cryptic" and "mechanical," noting that the age of an application (pending since 2022) is not a legally sustainable reason for rejection

By failing to assign substantive reasons or hear the merits regarding the legal heirs’ representation, the Trial Court acted in an arbitrary and unjust manner

The High Court determined that such procedural lapses necessitated intervention to ensure the plaintiff's right to pursue the suit against the deceased's estate was fairly adjudicated

The Trial Court was directed to restore Exhibits 21, 22, and 23 to its original file and decide them on their merits after providing all parties an effective opportunity to be heard. The Court further granted the respondents a 15-day window to seek recall or modification of this order if they were aggrieved, as the decision was reached without their presence