Reasonable cause for additional documents exists if they respond to new defenses or arose post-suit.

The plaintiff (DMRC) filed a recovery suit against the defendant for costs incurred due to alleged poor construction of staff quarters at Mundka Depot

Following occupation in 2013, residents reported sewage problems and structural cracks

DMRC engaged technical agencies (Shri Ram Institute, Epicon Consultants, CBRI) and a repair contractor, eventually dismantling and reconstructing the buildings

During the trial stage, DMRC filed an application under Order XI Rule 1(5) of the CPC to bring eight additional documents on record, including correspondence from 2015, a 2022 CBRI report, and records of payments made to repair agencies and for employee alternative accommodation

The defendant opposed the application, citing a lack of "reasonable cause" for the delay

Whether the plaintiff established "reasonable cause" for the non-disclosure of additional documents at the time of filing the plaint as required under Order XI Rule 1(5) of the CPC (as amended by the Commercial Courts Act)

Whether documents created or discovered after the filing of the suit are exempt from the rigors of establishing "reasonable cause" for prior non-disclosure

The court applied Order XI Rule 1 of the CPC, as amended by the Commercial Courts Act, 2015, which mandates the filing of all documents in the plaintiff's power/possession along with the plaint

Under Rule 1(1)(c)(ii), documents produced in answer to a case set up by the defendant subsequent to the plaint are exempted

Under Rule 1(5), additional documents require leave of court upon establishing "reasonable cause"

The court relied on *Sudhir Kumar v. Vinay Kumar G.B.* (2021), which held that the rigour of "reasonable cause" does not apply to documents found or created subsequent to the filing of the suit

It further applied *Agva Healthcare v. Agfa-Gevaert NV* (2023) and *Darrameks Hotels v. Brilltech Engineers* (2025), establishing that "reasonable cause" is an elastic term requiring a lower degree of proof than "sufficient cause," and that procedure should serve as the handmaid of justice

The Court categorized the eight documents into three groups.

First, letters from 2015 and the contract's dispute resolution clause were admitted under Order XI Rule 1(1)(c)(ii) because they were filed to rebut the defendant's specific written statement claims regarding work quality and a prior settlement

Second, the CBRI report (2022) and a Performance Certificate (2024) were admitted because they were created after the suit was filed, meaning they were never in the plaintiff’s prior possession

Third, for payment records (invoices and lease documents), the Court found "reasonable cause" despite some being pre-suit; the plaintiff had explicitly stated in the plaint that repair works were ongoing and total costs were then unascertainable

The Court reasoned that these documents were essential for quantifying damages—a core issue in a recovery suit—and their admission caused no prejudice as the defendant could cross-examine the witnesses on them

It held that documents essential for the adjudication of the dispute and those rebutting a defendant’s subsequent plea should be admitted liberally to ensure substantial justice

However, due to the belated nature of the filing, the Court imposed a cost of Rs. 20,000/- on the plaintiff, payable to the defendant’s counsel