1. Heard Sri Ravinder Reddy Muppu, learned counsel duly assisted by Sri B.Krishna Kumar, learned counsel on record for the petitioner and Sri Eranki Phani Kumar, learned counsel for the respondent No.1.

2.  The present Civil Revision Petition is filed assailing the common order dated 06.11.2025 (in I.A.Nos.563, 564 and 800 of 2025 in O.S.No.34 of 2021) passed by the learned Principal District Judge, Vikarabad District, (for short, ‘the Trial Court’) only to the extent of rejection of the claim of the petitioner in I.A.No.800 of 2025 in O.S.No.34 of 2021 in respect of the original agreement of sale dated 29.10.2020 shown at Serial No.1.

3.  The brief facts of the case are that the respondent No.1 herein, who is the plaintiff, filed O.S.No.34 of 2021 before the learned Trial Court against the petitioner herein and respondent Nos.2 and 3 herein/defendants for specific performance of agreement of sale by directing the defendants to execute a registered sale deed in respect of the suit schedule property in favour of the plaintiff by receiving balance sale consideration.

4.  During the pendency of the suit, the revision petitioner herein /defendant No.3 filed I.A.No.800 of 2025 under Order VIII Rule 1(A) read with Section 151 of the Code of Procedure, 1908 (CPC) to receive the list of documents filed in Form No.VII; I.A.No.563 of 2025 is filed under Order XVIII Rule 17 CPC to recall PW.1 for further limited cross-examination; and I.A.No.564 of 2025 is filed to reopen the evidence of the plaintiff.

5.  Upon clubbing all the three I.As., the learned Trial Court while allowing I.A.Nos.563 and 564 of 2025, partly allowed I.A.No.800 of 2025 and permitted the documents filed along with the said application at Serial Nos.2 to 5 to be received, subject to proof and relevancy. However, the claim in respect of original agreement of sale dated 29.10.2020 shown at Serial No.1 was rejected on the ground that it is inadmissible in evidence.

6.  Aggrieved by the rejection of the said document, the present Civil Revision Petition is filed.

7.  Learned counsel for the petitioner contends that the agreement of sale dated 29.10.2020 sought to be brought on record is only for the purpose of collateral purpose. It is further contended that the said agreement of sale is a material and relevant document for proper adjudication of the dispute between the parties and therefore, the learned Trial Court ought not to have declined to receive the same at the stage of granting leave to produce the document.

8.  Learned counsel further contends that the agreement of sale dated 29.10.2020 has subsequently merged in sale deed dated 08.02.2021. Therefore, according to the learned counsel, the question of payment of deficit stamp duty or the admissibility of the document does not arise at the stage of considering the application under Order VIII Rule 1-A(3) CPC and the document ought to have been permitted to be brought on record.

9.  Learned counsel also contends that the application filed under Order VIII Rule 1-A(3) CPC ought to have been considered within the limited parameters prescribed therein. Instead, the learned Trial Court has entered into the question of admissibility of the document, which is a matter to be considered at the stage when the document is tendered in evidence. It is, therefore, contended that the Trial Court has committed an error in rejecting the document at the threshold.

10. In support of his contentions, learned counsel relied upon a judgment of the Hon’ble Supreme Court in Muruganandam v/s. Muniyandi (2025 INSC 652), wherein it was held that an unregistered document can be received in evidence for collateral purpose in terms of Section 49 of the Registration Act, 1908.

11. Learned counsel also relied upon the judgment of the Hon’ble Apex Court in Levaku Pedda Reddamma v/s. Gottumukkala Venkata Subbamma (2022 LiveLaw (SC) 533), wherein it was held that rules of procedure are hand-maid of justice and therefore, even if there is some delay, the Trial Court should have imposed some costs rather than to decline the production of the documents itself. Hence, learned counsel prays to allow the CRP.

12. On the other hand, Sri Eranki Phani Kumar, learned counsel for the respondent No.1, denying the averments made by the petitioner and inter alia contending that the suit, which is filed in the year 2021, is still pending consideration; that respondent Nos.2 and 3 being lawful owners of the suit property offered to sell the property for a consideration of Rs.3,15,00,000 @ Rs.45,00,000/- per acre and thus entered into an agreement of sale on 05.12.2020 with the respondent No.1 herein; and that pursuant to the same, the respondent No.1 paid an amount of Rs.50,00,000/- towards part of sale consideration.

13. Learned counsel further contended that under the terms of agreement, respondent Nos.2 and 3 herein were required to undertake survey and measurement of the land, demarcate the same by fixing boundary stones and furnish the relevant link documents.; that though the respondent No.1 was ready and willing to perform his part of contract by paying the balance sale consideration within 100 days from the date of agreement of sale, respondent Nos.2 and 3 herein failed to comply with their obligations, despite his constant persuasion.

14. Learned counsel also contends that admittedly the petitioner herein did not file the alleged agreement of sale dated 29.10.2020 along with the written statement and that the contents of said agreement of sale give rise to serious doubt as regards its genuineness. It is therefore contended that the Trial Court was justified in declining to receive the said document and that no error of jurisdiction or illegality has been committed by the Trial Court warranting interference under Article 227 of the Constitution of India.

15. In support of his contentions, learned counsel relied upon the judgments of Hon’ble Supreme Court in Correspondence, RBANMS Educational Institution v/s. B.Gunashekar (AIR 2025 SUPREME COURT 2065) and another decision of erstwhile High Court of Andhra Pradesh at Hyderabad in Voruganti Narayana Rao v/s. Bodla Rammurthy (2011 (6) ALT 299) and accordingly, prays for dismissal of the CRP.

16. I have given my earnest consideration to the respective submissions made by the learned counsel appearing for the parties and perused the record.

17. A perusal of the record discloses that the petitioner herein, who is the defendant No.3 in the suit, has specifically pleaded in the written statement as to the existence of the agreement of sale dated 29.10.2020 in respect of the suit schedule property allegedly executed by the defendant Nos.1 and 2 in his favour. It is also his specific case that, when defendant Nos.1 and 2 started acting contrary to the terms of the said agreement, he lost confidence in them and consequently obtained the registered sale deed dated 08.02.2021, which was accepted for registration. Thus, the existence and relevance of the agreement of sale dated 29.10.2020 have already been specifically brought on record by way of pleadings.

18. A further perusal of the impugned order shows that the learned Trial Court permitted the petitioner to place on record the documents filed along with I.A.No.800 of 2025, except the agreement of sale dated 29.10.2020. The said document was excluded solely on the ground that it was unregistered and insufficiently stamped and consequently, inadmissible in evidence. However, the impugned order is cryptic without proper explanation as the Trial Court has not properly considered the distinction between permitting a party to produce a document and adjudicating upon its admissibility in evidence.

19. Admittedly, admissibility of the document cannot be decided at the stage of granting leave for filing. The scope of Order VIII Rule 1-A(3) CPC is confined to permitting production of documents which were not filed along with the written statement, subject to satisfactory explanation for such non-filing. However, granting leave to file documents and receiving them in evidence are distinct stages. While the former occurs at the stage of pleadings, the latter arises only at the stage of trial when the document is tendered and marked as an exhibit. At that juncture alone, the question of admissibility can be adjudicated.

20. In the present case, the existence of the agreement of sale has already been pleaded in the written statement. The defendant has offered a satisfactory explanation for its non-filing along with the written statement. The Trial Court accepted the explanation and granted leave for other documents, but excluded the agreement of sale solely on the ground of inadmissibility, which is unsustainable. Since photocopy of the document sought to be brought on record is only to be used as a proof and for collateral purpose, considering the judgment relied upon by the learned counsel for the petitioner in Muruganandam’s case (1 supra), wherein it was held that an unregistered document can be received in evidence as collateral purpose under Section 49 of the Registration Act and another judgment in Levaku Pedda Reddamma ‘s case (2 supra), wherein it was held that it is well settled that rules of procedure are hand-maid of justice and therefore, even if there is some delay, the Trial Court should have imposed some costs rather than to decline the production of the document itself.

21. For the foregoing reasons, this Court is of the considered view that the learned Trial Court committed an error in rejecting the agreement of sale dated 29.10.2020 at the stage of considering I.A.No.800 of 2025, solely on the ground of its alleged inadmissibility. Such an approach is not sustainable in law, particularly when the existence of the document has already been pleaded and the application for its production has otherwise been considered by the Trial Court.

22. Accordingly, the Civil Revision Petition is allowed with costs of Rs.10,000/- (Rupees Ten Thousand only) payable by the petitioner to the Telangana High Court Senior Officers Association, Hyderabad. The common order dated 06.11.2025 passed by the learned Principal District Judge, Vikarabad District, in I.A.No.800 of 2025 in O.S.No.34 of 2021 is set aside to the extent of rejection of the document at Serial No.1, viz., the agreement of sale dated 29.10.2020. The said document shall be taken on record, subject to proof and relevancy, and the question of its admissibility, including the effect of its registration and stamping, shall be considered by the Trial Court at the appropriate stage and in accordance with law. It is, however, made clear that the present order shall not be construed as a finding on the genuineness, execution, evidentiary value or ultimate admissibility of the said document, and the Trial Court shall independently consider those aspects at the stage of trial.

Pending miscellaneous petitions, if any, shall stand closed.