Limited remand confines trial court jurisdiction; additional documents beyond appellate directions cannot be admitted.

A trial court must act strictly within the terms of a limited remand; where the appellate court directs only one specified document to be admitted and proved, the court cannot enlarge the remand by allowing additional documents or new matters. The trial court's jurisdiction remains confined to the scope fixed by the remand order, and departure from those directions amounts to material irregularity. The impugned order permitting production of an extra document was therefore set aside.

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Issues: Whether, after a remand confined to admission and proof of a specified document, the trial court could permit production of an additional document beyond the scope of the remand.

Analysis: A remand may either be a general remand for retrial, in which the trial court may exercise the normal powers available in the original trial, or a limited remand where the appellate court prescribes the precise manner in which the matter is to proceed. Where the remand order specifically directs that a particular document be taken in evidence and the parties be allowed to prove or disprove that document, the trial court is bound by those directions and cannot enlarge its jurisdiction by entertaining fresh documents or other matters not covered by the remand.

Conclusion: The trial court acted beyond the scope of the remand and with material irregularity in allowing production of the additional document; the impugned order was set aside.

Ratio Decidendi: The jurisdiction of the court after remand is controlled by the terms of the remand order, and a limited remand does not permit the trial court to travel beyond the specific directions issued by the appellate court.

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