Procedural Technicalities or Invocation of Wrong Legal Provision Cannot Defeat Substantial Justice if Court Possesses Inherent Power

The Petitioner (Defendant No. 1 below) filed an application under Section 151 of the Code of Civil Procedure (CPC) before the Civil Judge (Senior Division), Pakyong, seeking leave to produce additional documents (electricity bills and Voter IDs).

These documents were intended to support a defense of impersonation against the Respondents.

The Trial Court rejected the application on November 27, 2025, primarily because the Petitioner invoked Section 151 (inherent powers) instead of the specific procedural provisions for filing documents post-written statement, and allegedly failed to disclose the source or possession of said documents.

The Petitioner approached the High Court under Article 227 of the Constitution challenging this rejection.

1. Whether the invocation of an incorrect provision of law (Section 151 CPC) is fatal to an application for filing additional documents when the power to grant such relief exists.

2. Whether procedural technicalities should override the pursuit of substantial justice and the discovery of truth in a trial.

The Court applied the principle that procedure is the "handmaid of justice," relying on Sugandhi v. P. Rajkumar (2020) which held that procedural lapses should not obstruct substantial justice if they do not cause serious prejudice.

It cited Pruthvirajsinh Nodhubha Jadeja v. Jayeshkumar Chhakaddas Shah (2019) to establish that non-mentioning or mis-mentioning of a provision is not fatal if the Court possesses the inherent power to pass the order.

Further, the Court referenced Rani Kusum v. Kanchan Devi (2005) and M/s Anvita Auto Tech Works Pvt. Ltd. v. M/s Aroush Motors (2025) to reiterate that processual law is a servant/aid to justice, not a tyrant or obstruction.

The Court reasoned that while the Trial Court was correct that the Petitioner lacked diligence in invoking the proper provision, this technicality alone should not deprive a party of the opportunity to fortify their case, especially since the trial was at a "nascent stage".

The Court noted that the Petitioner had previously obtained a court order to summon the Election Department for these documents, demonstrating active efforts to secure evidence.

It rejected the Respondent's argument that the documents weren't mentioned in the Written Statement, pointing out that Paragraph 16 of the defense specifically referenced the Electoral Identity Cards.

The Court emphasized that a trial is a "journey towards truth" and courts must take a lenient view of document production applications to ensure even-handed justice.

The Court disposed of the Revision Petition by granting the Petitioner leave to re-file the application before the Trial Court using the correct legal provisions; consequently, the stay on the original Title Suit No. 09 of 2024 was vacated, and the Trial Court was directed to consider the new application as per law.