Madanlal vs Shyamlal

The Supreme Court upheld the High Court's dismissal of the appellant's revision petition regarding the rejection of his application to produce additional documents under Order 13 Rule 2 of the CPC. The Court emphasized that the appellant failed to show a 'good cause' for the late production of documents, as required by the rule, and that the trial court's decision did not constitute a material irregularity under Section 115 of the CPC. The judgment reaffirmed the principle that the power to allow late document production should be exercised judiciously and that errors of fact or law do not amount to material irregularities.