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Case Law (Purpose of Order XI, Rule 21, C.P.C. with regard to discovery of documents.................)

Purpose of Order XI, Rule 21, C.P.C. with regard to discovery of documents on oath is to compel the opposing party to disclose all documents that he relies on so that the other side is not surprised later.

1999 CLC 356

(a) Civil Procedure Code (V of 1908)‑‑‑

‑‑‑‑O. XI, R.21‑‑‑Provisions of O.XI, R.21, C.P.C. are penal in nature‑‑ Application of O.XI, R.21, C.P.C.‑‑‑Ingredients.

Provisions of Order XI, Rule 21, C.P.C. being penal in nature, these are to be strictly construed. For this provision to be applicable, it is necessary that:

(1) There should be a specific order of the Court for filing of affidavit of documents.

(2) The defaulting party wilfully fails to comply with the order.

Mrs. Bilqees Rehman v. Anjum Hameed 1988 SCMR 80 ref.

(b) Civil Procedure Code (V of 1908)‑‑‑

‑‑‑‑O. XI, R.21‑‑‑Purpose of O.XI, R.21, C.P.C.‑‑‑Non‑compliance with order of discovery of document‑‑‑Effect.

Purpose of Order XI, Rule 21, C.P.C. with regard to discovery of documents on oath is to compel the opposing party to disclose all documents that he relies on so that the other side is not surprised later. It also serves to nip the evil in bud, as it were, inasmuch as frivolous proceedings can be summarily disposed of at an early stage. But since the penalty for non‑compliance with this provision is so stringent, it is necessary that the penal provision must be strictly construed and the party concerned must be non‑suited only if the abovementioned ingredients are fully met. The tenor of law is such that it contemplates, purposeful avoidance or refusal by the party concerned to file the affidavit of documents with mala fide motives. If thus, mere technicality regarding the discovery, not being in accordance with a certain format, is allowed to non‑suit a party, it will be travesty of justice.

(c) Civil Procedure Code (V of 1908)‑‑‑

‑‑‑‑O. XI, Rr.12 & 21‑‑‑Application for discovery of documents‑‑‑Defendant did not disclose documents in affidavit‑‑‑Plaintiff objected that affidavit was not in accord with rules‑‑‑Affidavit was neither rejected nor order for filing of fresh affidavit was passed‑‑‑Parties should have been directed to file fresh affidavits in circumstances‑‑‑In absence of such orders, affidavit would be deemed to have been accepted albeit at the risk of party concerned and Court may draw adverse inference at time of trial‑‑‑Such fact would by no means constitute wilful failure to comply with orders of Court.

Hussain Ali J. Merchant for Plaintiff (in Suit No.432 of 1994 and C.M.A. No. 1614 of 1995).

Nemo for Respondent No.l (in Suit No.432 of 1994 and C.M.A. No. 1614 of 1995).

Muhammad Ilyas Khan for Defendant No.2 (in Suit No.432 of 1994 and C.M.A. No. 1614 of 1995).

Muhammad Jamil Ahmed for Plaintiff (in Suit No.759 of 1997 and C.M.A. No.4559 of 1998).

Zia Qureshi for Defendants (in Suit No.759 of 1997 and C.M.A. No.4559 of 1998).

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