Facts
The appellant and the respondent bank entered into an IT Professional Services Agreement for development and management of a mobile application. After disputes arose regarding revenue sharing, the appellant instituted a civil suit before the Delhi High Court seeking recovery of dues. During the course of trial, after the examination of its first witness had concluded, the appellant sought leave under Order XI Rules 1 & 5 and Order XVIII Rule 17 CPC (as amended by the Commercial Courts Act, 2015 (CCA)) to produce additional documents and recall its witness. The High Court rejected the application for lack of reasonable cause. The appellant challenged that order before the Supreme Court.
Issues Framed
(a) Whether the appellant had shown a reasonable cause for producing additional documents after commencement of evidence in a commercial suit.
(b) Whether the High Court rightly rejected the application under the scheme of the Commercial Courts Act, 2015.
Court's Reasoning
(a) The Court emphasised that the CCA is intended to ensure speedy adjudication of commercial disputes through strict procedural timelines. The provisions relating to disclosure and production of documents must therefore be construed strictly.
(b) Under Order XI Rule 1 CPC, a plaintiff seeking to rely upon additional documents must establish a reasonable cause for not producing them earlier. The documents sought to be introduced were admittedly in the appellant's possession when the suit was instituted and even when an earlier application for additional documents had been allowed.
(c) The explanations offered—large volume of emails, extensive records and matters emerging during cross-examination—did not constitute a reasonable cause. A plaintiff is expected to present its complete documentary case at the appropriate stage and cannot adopt a "stop and go" or piecemeal approach to evidence.
(d) The Court rejected the contention that the stricter procedural regime of the CCA did not apply because the suit had originally been filed before enactment of the commercial procedure. By virtue of S.15 CCA, the amended procedure applies to pending commercial suits after their transfer or renumbering.
Held
The appeal was dismissed. The High Court correctly refused leave to produce additional documents, and the suit was directed to be decided expeditiously.
Ratio
A plaintiff cannot be permitted to introduce documents in a piecemeal manner without establishing a reasonable cause for earlier non-disclosure.
Case Details
Citation: 2026 INSC 674
Decided on: 09 July 2026
Case Title: M/s. Levitate Mobile Technologies Pvt. Ltd. v. M/s. Standard Chartered Bank & Anr.
Court: Supreme Court of India
Bench: Sanjay Karol, J.; Nongmeikapam Kotiswar Singh, J.