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The Supreme Court held that an Order XVIII Rule 17 application is limited to court-identified clarification and cannot be used to recall a witness or reopen evidence after trial closure. Litigants can no longer seek post-trial witness recall through this provision.
The Andhra Pradesh High Court ruled that genuine medical incapacity constitutes a valid ground for non-compliance with a conditional order to reopen evidence, emphasizing that courts must prioritize complete justice over procedural technicalities under Section 151 CPC. This holding reinforces the discretionary power of courts to prevent injustice where compliance is rendered impossible due to unforeseen circumstances.
Madras High Court holds that trial courts must permit reopening of evidence and recall of witnesses if additional documents like an FIR are material to the case. The ruling reinforces that fair trial rights under Article 227 override procedural technicalities, ensuring substantive justice in commercial disputes.