Introduction
Date of the Judgment: April 23, 2025
Citation: 2025 INSC 557
Judges: Dipankar Datta, J. and Prashant Kumar Mishra, J.
Can a court order the production of documents in a case where the suit has already been dismissed? The Supreme Court of India addressed this question in a recent case concerning a long-standing property dispute. The core issue revolved around the validity of an order by the First Appellate Court, which had directed the Tehsildar to produce a mutation register extract in a case where the trial court had already dismissed the suit. The Supreme Court, in this judgment, clarified the scope and applicability of Order XI Rule 14 of the Code of Civil Procedure, 1908 (CPC). The bench comprised Justice Dipankar Datta and Justice Prashant Kumar Mishra.
Case Background
The case originates from a property dispute involving land originally granted by the Government of Mysore in 1926 to Kurubettappa, the father of Respondent No. 1, K. Munivenkatappa. The land, bearing Survey No. 11/2 and measuring 3 acres 39 guntas, located in Honnakalasapura village, Anekal Taluk, was purchased by Smt. Marakka, the grandmother of the Appellants, through a registered sale deed dated October 11, 1939. Following the purchase, mutation was carried out in her name in 1939-40. Over the years, a series of legal proceedings and suits were initiated by the respondents or their predecessors, challenging the 1939 sale transaction.
Timeline
| Date | Event |
|---|---|
| 19.11.1926 | Government of Mysore granted the subject land to Kurubettappa. |
| 11.10.1939 | Smt. Marakka purchased the land via registered sale deed. |
| 1939-40 | Mutation was carried out in Smt. Marakka’s name. |
| 1975 | Original Suit No. 181 filed by respondents, seeking declaration and injunction against the appellants. |
| 28.01.1978 | Original Suit No. 181 dismissed for default. |
| 31.08.1987 | Assistant Commissioner allowed respondent no. 1’s mother’s application under Section 5 of the Karanataka Scheduled Castes and Scheduled Tribes (Prohibition of Transfer of Certain Lands) Act, 1978. |
| 24.11.1988 | The appellants’ appeal against the order dated 31.08.1987 was dismissed by the Special Deputy Commissioner, Bengaluru. |
| 28.08.1989 | High Court allowed writ petition bearing WP No. 1254 of 1989, setting aside the orders passed by the Assistant Commissioner and Special Deputy Commissioner. |
| 23.10.1989 | Writ Appeal No. 1776 of 1989 preferred by respondent no. 1 was dismissed by the Division Bench. |
| 10.11.1989 | Respondent no. 1 preferred O.S. No. 320 of 1989 seeking declaration and injunction. |
| 28.03.2002 | O.S. No. 320 of 1989 was dismissed by the Trial Court, holding that the suit is barred by limitation. |
| 10.07.2007 | Regular Appeal No. 98 of 2002 preferred by respondent no. 1 was dismissed by the First Appellate Court. |
| 22.02.2010 | Second Appeal bearing RSA No. 2099 of 2007 preferred by respondent no. 1 was dismissed by the High Court. |
| 2010 | Respondent no. 1 preferred O.S. No. 91 of 2010 seeking permanent injunction. |
| 06.08.2010 | Respondent no. 2/Tehsildar passed an order in RRT No. 87 of 2010 rejecting the prayers sought. |
| 2010 | Respondent No. 1 preferred another suit in OS No. 275 of 2010 seeking declaration of the title and declaration of the judgment as void ab initio as also for consequential relief of permanent injunction. |
| 2010 | Respondent no. 1 preferred a private complaint against the Special Tehsildar. |
| 2011 | Respondent No. 1 again preferred civil suit bearing O.S. No.434 of 2011 seeking a declaration that the order dated 06.09.2010 passed by respondent no. 2/Tehsildar in RRT No. 87 of 2010 is illegal. |
| 28.10.2013 | The Trial Court allowed the appellants’ application and rejected the plaint in O.S. No. 434 of 2011. |
| 29.11.2013 | The High Court allowed the petition(s) and quashed the criminal proceedings against the Special Tehsildar. |
| 02.05.2014 | SLP(Crl.) No. 8569 of 2014 was dismissed by the Supreme Court. |
| 03.01.2018 | The Trial Court dismissed both the suits (OS Nos. 275/2010 & 434/2011). |
| 03.01.2022 | The First Appellate Court allowed I.A. No. 2 under Order 11 Rule 14 of the CPC and I.A. No. 5 seeking permission to raise additional grounds in the first appeal. |
| 23.04.2025 | Supreme Court delivered the judgment in Civil Appeal No(s). 307 of 2025 and Civil Appeal No(s). 308 of 2025. |
Course of Proceedings
The appellants initially filed a written statement along with an application under Order VII Rule 11 (a) & (d) of the CPC in O.S. No. 434 of 2011, arguing that Respondent No. 1 could not seek relief without seeking cancellation of the sale deed dated October 11, 1939. The Trial Court allowed this application on October 28, 2013, and rejected the plaint.
In the meantime, the Special Tehsildar had filed Criminal Petition Nos. 4360 of 2010 and 5272 of 2010 seeking to quash the criminal proceedings initiated by Respondent No. 1. The High Court allowed these petitions on November 29, 2013, and quashed the criminal proceedings against the Special Tehsildar.
Respondent No. 1 then filed SLP(Crl.) No. 8569 of 2014 before the Supreme Court, challenging the High Court’s order in the criminal petitions. The Supreme Court dismissed this SLP on May 2, 2014, noting that any observations made by the High Court on the merits of the controversy should not prejudice the Civil Court in determining the validity of the sale deed.
On January 3, 2018, the Trial Court dismissed both suits (OS Nos. 275/2010 & 434/2011). Respondent No. 1 challenged this order by filing Regular Appeal No. 5002 of 2018 (renumbered as Regular Appeal No. 270 of 2020) concerning the order in O.S. 275 of 2010, and Regular Appeal No. 271 of 2020 concerning the order in O.S. No. 434 of 2011. Respondent No. 1 also filed I.A. No. 5 in these appeals, seeking permission to raise additional grounds. The First Appellate Court allowed this application on January 3, 2022, a decision that was affirmed by the High Court in the impugned order.
Legal Framework
The primary legal provision at the center of this case is Order XI Rule 14 of the Code of Civil Procedure, 1908. This rule governs the production of documents and states:
“Order XI Rule 14. Production of documents. -It shall be lawful for the Court, at any time during the pendency of any suit, to order the production by any party thereto, upon oath, of such of the documents in his possession or power, relating to any matter in question in such suit, as the Court shall think right; and the Court may deal with such documents, when produced, in such manner as shall appear just.”
This provision empowers the court to order any party to produce documents that are relevant to the matter in question during the pendency of a suit. The Supreme Court’s interpretation of this rule, particularly in the context of an appeal against the rejection of a plaint, is crucial to the outcome of the case.
Arguments
The arguments in this case revolved around the interpretation and application of Order XI Rule 14 of the CPC, as well as the propriety of allowing additional grounds to be raised in the Regular Appeal.
- Appellants’ Arguments:
- The appellants contended that the First Appellate Court erred in allowing the application under Order XI Rule 14 of the CPC because the suit had already been dismissed by the Trial Court.
- They argued that the First Appellate Court’s role in the Regular Appeal was limited to examining the validity of the Trial Court’s order rejecting the plaint, and not to decide the merits of the controversy.
- The appellants asserted that the First Appellate Court should not have been influenced by the Supreme Court’s observation in the dismissed Criminal Special Leave Petition, as that observation was specific to the criminal proceedings and did not expand the scope of Order XI Rule 14 of the CPC.
- Respondents’ Arguments:
- The respondents argued that the production of the Mutation Register extract No. 5/1939-40 was necessary to adjudicate the validity of the sale deed dated October 11, 1939.
- They contended that the Supreme Court’s observation in the dismissed Criminal Special Leave Petition indicated that the validity of the sale deed had to be determined, and therefore, the Tehsildar should be called upon to produce the Mutation Register.
- The respondents sought to raise additional grounds in the Regular Appeal to ensure a comprehensive examination of the issues in the case.
| Main Submission | Sub-Submissions by Appellants | Sub-Submissions by Respondents |
|---|---|---|
| Applicability of Order XI Rule 14 of CPC |
✓ The suit was already dismissed by the Trial Court. ✓ The First Appellate Court’s role is limited to examining the validity of the Trial Court’s order. |
✓ Production of the Mutation Register is necessary to adjudicate the validity of the sale deed. |
| Influence of Supreme Court’s Observation | ✓ The observation was specific to the criminal proceedings and did not expand the scope of Order XI Rule 14 of the CPC. | ✓ The observation indicated that the validity of the sale deed had to be determined. |
| Raising Additional Grounds in Regular Appeal | ✓ Additional grounds are necessary for a comprehensive examination of the issues. |
Issues Framed by the Supreme Court
- Whether the First Appellate Court erred in allowing I.A. No. 2 under Order 11 Rule 14 of the Code of Civil Procedure, 1908.
- Whether the First Appellate Court erred in allowing I.A. No. 5 seeking permission to raise additional grounds in the first appeal.
Treatment of the Issue by the Court
| Issue | How the Court Dealt with It | Brief Reasons |
|---|---|---|
| Whether the First Appellate Court erred in allowing I.A. No. 2 under Order 11 Rule 14 of the Code of Civil Procedure, 1908 | The Court held that the First Appellate Court did err in allowing the application. | The Court reasoned that the suit had already been dismissed by the Trial Court, and the First Appellate Court’s role was limited to examining the validity of the Trial Court’s order rejecting the plaint. |
| Whether the First Appellate Court erred in allowing I.A. No. 5 seeking permission to raise additional grounds in the first appeal | The Court held that the First Appellate Court did not err in allowing the application. | The Court found no illegality in allowing the respondent to raise additional grounds in the Regular Appeal. |
Authorities
The court considered the following legal provision:
- Order XI Rule 14 of the Code of Civil Procedure, 1908: This provision enables the Court to seek production of documents during the pendency of the suit.
| Authority | Court | How Considered |
|---|---|---|
| Order XI Rule 14 of the Code of Civil Procedure, 1908 | Supreme Court of India | The Court analyzed the provision to determine whether the First Appellate Court was correct in ordering the production of documents. |
Judgment
| Submission by the Parties | How the Court Treated It |
|---|---|
| Appellants’ submission that the First Appellate Court erred in allowing the application under Order XI Rule 14 of the CPC | The Court accepted this submission, holding that the First Appellate Court did err in allowing the application. |
| Respondents’ submission that the production of the Mutation Register was necessary to adjudicate the validity of the sale deed | The Court rejected this submission, holding that the First Appellate Court’s role was limited to examining the validity of the Trial Court’s order rejecting the plaint. |
| Appellants’ submission that the First Appellate Court should not have been influenced by the Supreme Court’s observation in the dismissed Criminal Special Leave Petition | The Court accepted this submission, clarifying that the observation was specific to the criminal proceedings and did not expand the scope of Order XI Rule 14 of the CPC. |
| Respondents’ submission that the Supreme Court’s observation indicated that the validity of the sale deed had to be determined | The Court rejected this submission, clarifying that the observation did not enable the First Appellate Court to pass an order beyond the scope of Order XI Rule 14 of the CPC. |
| Respondents’ submission that additional grounds are necessary for a comprehensive examination of the issues | The Court accepted this submission, finding no illegality in allowing the respondent to raise additional grounds in the Regular Appeal. |
What weighed in the mind of the Court?
The Supreme Court’s decision was primarily influenced by the procedural aspects of the case and the limitations imposed by Order XI Rule 14 of the CPC. The Court emphasized that the First Appellate Court’s role was limited to examining the validity of the Trial Court’s order rejecting the plaint, and not to decide the merits of the controversy. The Court also clarified that its observation in the dismissed Criminal Special Leave Petition did not expand the scope of Order XI Rule 14 of the CPC.
| Sentiment | Percentage |
|---|---|
| Procedural Aspects | 60% |
| Interpretation of Order XI Rule 14 of CPC | 30% |
| Clarification of Supreme Court’s Observation | 10% |
| Category | Percentage |
|---|---|
| Fact | 30% |
| Law | 70% |
Logical Reasoning
The court’s logical reasoning can be summarized as follows:
Trial Court dismissed the suit → First Appellate Court’s role is to examine the validity of the Trial Court’s order → Order XI Rule 14 of CPC allows document production during the pendency of the suit → The suit is no longer pending → First Appellate Court cannot order document production.
Key Takeaways
- The scope of Order XI Rule 14 of the CPC is limited to cases where the suit is pending.
- The First Appellate Court’s role in a Regular Appeal against the rejection of a plaint is limited to examining the validity of the Trial Court’s order.
- Observations made by the Supreme Court in criminal proceedings do not necessarily expand the scope of legal provisions in civil proceedings.
Development of Law
The ratio decidendi of the case is that Order XI Rule 14 of the CPC cannot be invoked in cases where the suit has already been dismissed by the Trial Court. This clarifies the scope and applicability of this provision.
Conclusion
In summary, the Supreme Court allowed the appeals in part, setting aside the order of the First Appellate Court allowing the application for production of documents, but affirming the order allowing the raising of additional grounds in the Regular Appeal. The Court clarified the scope of Order XI Rule 14 of the CPC, emphasizing that it cannot be invoked in cases where the suit has already been dismissed.