Section 145 filing deadlines control supporting material, but formal affidavit defects may be cured in appropriate cases.

Proceedings under Section 145 are meant to be completed expeditiously, so the time fixed by the Magistrate generally governs both written statements and the documents and affidavits supporting them. Additional documents filed after the fixed time are not admissible as of right, though the Magistrate may, in exceptional cases and on sufficient cause shown, accept them in the interests of justice. A defect in attestation of affidavits already filed within time is a curable irregularity, and proper attestation may be permitted without affecting the substantive requirements of the provision.

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Issues: (i) Whether additional documents could be permitted to be filed in proceedings under Section 145 after expiry of the time fixed by the Magistrate; (ii) Whether defective affidavits filed within time could be rectified by proper attestation.

Issue (i): Whether additional documents could be permitted to be filed in proceedings under Section 145 after expiry of the time fixed by the Magistrate.

Analysis: Proceedings under Section 145 are intended to be completed expeditiously, and the time fixed by the Magistrate applies to the filing of written statements as well as the documents and affidavits on which the parties rely. Permitting further documents at a later stage would ordinarily defeat the object of the provision. At the same time, the nature of the proceeding is quasi-civil, and in exceptional cases the Magistrate may exercise discretion in the ends of justice if sufficient and valid reasons are shown for the earlier omission.

Conclusion: Additional documents were not as of right admissible after expiry of the time fixed, but the Magistrate retained a limited discretion to accept them if the party satisfied the Court of sufficient cause.

Issue (ii): Whether defective affidavits filed within time could be rectified by proper attestation.

Analysis: A defect in attestation of affidavits already filed along with the written statements was treated as an irregularity capable of correction. Allowing proper attestation would not infringe the substantive requirements of the section and would only cure a formal defect in material already placed before the Magistrate.

Conclusion: The affidavits could be rectified by permitting proper attestation.

Final Conclusion: The revision was not successful overall, though the Court recognised a limited power to cure defective affidavits and, in appropriate circumstances, to receive belated documents on sufficient cause being shown.

Ratio Decidendi: In proceedings under Section 145, the time fixed for filing material generally governs both statements and supporting documents, but the Magistrate may, in exceptional cases and in the ends of justice, cure formal defects or admit late documents on sufficient cause being shown.

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