Trial Court Erred in Denying Fresh Evidence Post-Amendment and Disregarding Public Documents in Evidence.

The appellants (plaintiffs), sons of late Ramanuj Lal Shrivastava, challenged a trial court judgment dismissing their suit to declare a 2009 sale deed null and void

The property in question, Plot No. 930, was sold by their mother (Respondent 1) to a third party (Respondent 2) based on a purported 2005 Will

In prior litigation involving the family, the appellate court had already declared the underlying Wills to be disproved and void—a finding the parties later accepted in a compromise decree before the High Court

The trial court in the present suit refused to consider the previous judgments, closed the plaintiffs' evidence prematurely despite earlier orders allowing it, and rejected applications to bring the second Will into the record

1. Whether the trial court erred in failing to consider the legal effect of previous judgments and compromise decrees that declared the underlying Wills void

2. Whether the trial court’s procedural conduct in closing the plaintiffs' evidence and rejecting the recall of witnesses resulted in a miscarriage of justice

The court applied principles governing the relevance of prior judgments under the Indian Evidence Act, noting that certified copies of court judgments are public documents that courts ought to take into consideration

The court further relied on the Code of Civil Procedure (CPC), specifically Order 18 Rule 17 regarding the power to recall and examine witnesses to ensure complete adjudication

The court relied on Order 23 Rule 1(4) regarding the impact of previous suits on maintainability

The High Court found that the trial court acted with "undue haste" to dispose of an old case, leading to significant procedural lapses

Specifically, the trial court ignored its own order dated 02.12.2021 which had re-fixed the case for plaintiff evidence following an amendment to the pleadings

By treating the evidence as closed based on an outdated date, the trial court deprived the appellants of a fair opportunity to prove their case

The High Court noted that the trial court "shoddily" answered issues regarding the previous litigation, failing to recognize that the Wills supporting the mother's title had already been judicially invalidated

The court reasoned that a meaningful adjudication was impossible without examining the second Will and the binding nature of the previous appellate decrees

It held that the trial court must grant the plaintiffs an opportunity to lead evidence as previously ordered and must take the second Will and previous judicial records into consideration

The trial court is directed to answer all issues afresh, including the impact of the prior declarations of the Wills as void, and complete the trial within six months

The appeal was partly allowed