Admission of additional evidence may be required where belated documents are bona fide and justice demands fresh consideration.

Relevant documents produced belatedly should not defeat substantive adjudication where there is no lack of bona fides. The High Court applied the principle governing admission of additional evidence and held that the appellate authority ought to have extended time for receipt of the documents and directed reconsideration by the original authority after taking them into account. It treated admission of the documents as consistent with natural justice and the ends of justice, since the dispute turned only on the timing of production and a sufficient explanation existed. The impugned order was set aside and the matter remitted for fresh consideration on merits after hearing both sides.

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Issues: Whether the appellate authority should have admitted the documents produced belatedly and afforded the petitioner an opportunity to have the project import contract reconsidered afresh.

Analysis: The Court found that the relevant documents had in fact been produced and there was no lack of bona fide. It held that the appellate authority ought to have extended time for receipt of the documents and should have directed reconsideration by the original authority after taking the documents into account. The Court relied on the principle underlying admission of additional evidence and treated it as consistent with the ends of justice and the principles of natural justice. Since the only issue was the timing of production of documents, the matter should not fail on that ground alone where sufficient explanation existed.

Conclusion: The refusal to admit the documents was not sustained and the matter was sent back for fresh consideration on merits after giving both sides an opportunity of hearing.

Final Conclusion: The impugned order was set aside and the customs authority was required to reconsider the matter afresh after admitting the documents and proceeding in accordance with law.

Ratio Decidendi: Where relevant documents are produced with no absence of bona fides, a belated filing should not defeat substantive consideration, and additional evidence may be admitted in aid of natural justice and fair adjudication.

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