Supreme Court of India· 14 August 2026

Did the redaction exercise undertaken by the High Court correctly distinguish between the fact that internal discussions took place and the contents of the internal e-mails recording those discussions?

RELIANCE INDUSTRIES LIMITED v. NTPC LIMITED

2026 INSC 862 · SLP (C) No. 23417 of 2024
Coram: Pamidighantam Sri Narasimha; Alok Aradhe

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Answer

Yes. Consistently with this Court's 2019 ruling, the High Court retained portions of the Evidence Affidavits reflecting the witness's own perception and state of mind while redacting portions that would bring the contents of internal e-mails on record indirectly.

Headnote

Indian Evidence Act, 1872 — Section 60 — res judicata — oral evidence — Evidence Affidavits — costs — res judicata — finality — Section 60 — Held: This Court's judgment dated 28th February 2019 restricting oral evidence about internal communications already excluded from the Evidence Affidavits had attained finality and bound the trial court, which could not reopen the issue by an indirect method. (¶13-14) Evidence Affidavits — internal e-mails — oral evidence — Held further: Applying that mandate, the High Court rightly retained portions of the affidavits reflecting the witness's perception of correspondence while redacting portions that would bring the contents of internal e-mails on record indirectly. (¶14, ¶16, ¶19) finality — costs — Held further: Having already settled the scope of admissible oral evidence in 2019, this Court declined to revisit that judgment, upheld the High Court's redaction, and dismissed the appeal with costs of Rs. 10 lakhs for prolonging a two-decade-old suit. (¶20, ¶23)

In the Court's own words

Paragraph 14Thus, this Court ruled that it was not open for the High Court to permit oral evidence with respect to the contents of the documents which have not been taken on record. That once the internal discussions were held to be irrelevant and documents were refused to be taken on record, the parties could not be permitted to adduce oral evidence qua said documents. This is the decision of this Court between the same parties. The mandate of Supreme Court order is that; (i) the evidence as to the inter se noting or correspondence between the officers was irrelevant, (ii) the documents which were not between the plaintiff and the defendant were not to be taken on record,

Paragraph 16Following the mandate of this Court, the High Court proceeded to examine portions of 1st Evidence Affidavit dated 24th February, 2015 and the 2nd Evidence Affidavit dated 10th August, 2016 which fell within the ambit of the matters expressly excluded by the Supreme Court. The High Court examined the affidavits in detail to see if they passed the test laid down by this Court. It will be useful to reproduce the exercise undertaken by the High Court as it is, in our opinion, a meticulous scrutiny of the issue. The consideration is as follows;

Paragraph 19Having considered the matter in detail, we are of the opinion that High Court has neither committed any error in understanding the directions of this Court nor in applying its mandate to the 1st and 2nd Evidence Affidavits.

Acts & Sections

Indian Evidence Act, 1872

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Also decided in this judgment

Whether the High Court, in giving effect to this Court's earlier judgment restricting the oral evidence that could be led from the Evidence Affidavits, was bound by that judgment as res judicata?Could the appellant reopen, under Section 60 of the Indian Evidence Act, 1872, the question of admissibility of oral evidence already settled by this Court's final order?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections