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As per case facts, respondents (plaintiffs) initiated a suit for specific performance, vacant possession, and declaration of ownership concerning a land agreement. During the first appeal, they sought to introduce
...additional evidence, specifically for a Forensic Science Laboratory to examine the original sale agreement and its copy due to alleged interpolation. The District Judge rejected this application, but the High Court, in a revision petition, overturned this decision and allowed the additional evidence. The question arose whether the High Court, in its revisional jurisdiction, was correct in interfering with the first appellate court's discretionary order denying the admission of additional evidence under Order XLI, Rule 27 CPC, particularly when the appellate court itself had not deemed such evidence necessary to pronounce judgment. Finally, the Supreme Court ruled that the High Court's interference was erroneous. The Court reiterated that the power to admit additional evidence in appeal is limited and discretionary, to be exercised only if the trial court refused admissible evidence, if new evidence could not be produced despite due diligence, or if the appellate court *requires* it to pronounce judgment or for other substantial cause. The mere existence of new scientific facilities or a desire for a more detailed inquiry, without the appellate court's specific requirement for judgment pronouncement, does not justify admitting additional evidence. The High Court wrongly re-examined the necessity as if it were an original proceeding, exceeding its revisional scope.
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