Logo
Court Book - India Code App - Play Store

advertisement

Telangana High Court Sets Aside Commercial Court Orders Allowing Late Filing of Documents Citing Strict Disclosure Rules Under 2015 Commercial Courts Act

Vivek G.

M/s Sri Vishnu Constructions vs. State of Telangana & Others, Telangana High Court overturns Commercial Court orders allowing late documents in construction payment suits, stressing strict disclosure rules under commercial law.

Telangana High Court Sets Aside Commercial Court Orders Allowing Late Filing of Documents Citing Strict Disclosure Rules Under 2015 Commercial Courts Act

The Telangana High Court on Thursday set aside two orders of the Ranga Reddy Commercial Court that had allowed government authorities to file documents nearly three years after submitting their written statements. The division bench, hearing the matter with quiet intensity through the afternoon, repeatedly questioned whether “misplaced documents” could be stretched into a legally acceptable excuse.

हिंदी में पढ़ें

Background

The dispute stems from two commercial suits filed by M/s Sri Vishnu Constructions, seeking recovery of more than ₹14 crore combined, relating to alleged outstanding payments in government works. The State and its departments, acting as defendants, had failed to file their documents at the required stage-even though they were referred to in their written statements.

Read also: Karnataka High Court Quashes Caste-Probe Orders Against Retired Headmaster, Calls Civil Rights Cell

Years passed. Evidence progressed. Witnesses were examined. The defendants’ chance to present evidence was even forfeited at one point. Then came a sudden flurry of applications: officials claimed the documents were “misplaced” and had been found only during a later search. The Commercial Court accepted this explanation and allowed most of them to be placed on record. Sri Vishnu Constructions

Court’s Observations

The High Court bench, comprising Justice Moushumi Bhattacharya and Justice Gadi Praveen Kumar, took a far tougher view of the situation.

The judges noted that the 2015 Commercial Courts Act brought in strict disclosure obligations, requiring all documents in a party’s “power, possession, control or custody” to be filed along with the written statement. Mere mention in pleadings does not satisfy the law.

Read also: Gauhati High Court Partly Allows Appeals, Grants Only Retrospective Salary Benefits to Former

At one point, Justice Bhattacharya remarked, “The statute demands diligence. A defendant cannot turn non-compliance into justification merely by saying the documents were referenced earlier.” Sri Vishnu Constructions

The bench emphasised that under Order XI Rule 1(10), additional documents can be brought later only if “reasonable cause” is proved—an intentionally high threshold. Simply saying papers were misplaced, the judges observed, falls far short of that requirement.

The court also rejected the Commercial Court’s reasoning that the plaintiff had not denied the relevance of the documents. “Relevance is not the test,” the bench observed. “Compliance with mandatory procedure is.” Sri Vishnu Constructions

Read also: Rajasthan High Court Orders Transfer of 63 Tribal Constables to TSP Areas After Years of Delay

Decision

In the end, the High Court held that the Commercial Court had “erred in law” by relaxing statutory requirements without any real justification.

Both revision petitions filed by Sri Vishnu Constructions were allowed, and the orders dated 10 June 2025 permitting the delayed documents were set aside in full.

The matter will now proceed without those belated documents forming part of the record. Sri Vishnu Constructions

Case Title: M/s Sri Vishnu Constructions vs. State of Telangana & Others

Case Numbers: Civil Revision Petition Nos. 2677 and 2572 of 2025

Case Type: Civil Revision Petitions arising from Commercial Court orders

Decision Date: 14 November 2025

Advertisment