Additional evidence at appeal stage requires due diligence, relevance, and a recognised legal ground; bare requests fail.

Additional documents cannot be received at the appellate stage unless the applicant satisfies a recognised ground for additional evidence, such as refusal of admissible evidence, due diligence, necessity for the appellate forum to pronounce judgment, or other substantial cause. Here, the request was unsupported by any explanation for the delay, the relevance of the documents, or the inability to produce them earlier, and the Tribunal noted that the assertions were contrary to the record. On that basis, the application for leave to place additional documents on record was found not maintainable and was dismissed.

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Issues: Whether the appellants were entitled to place additional documents on record at the appellate stage under the conditions governing additional evidence.

Analysis: The application sought leave to file additional documents without explaining the delay, the relevance of the documents, or why they could not be produced earlier before the adjudicating authority. The Tribunal found that the factual assertions made in the application were contrary to the record and that no direction had been issued requiring the filing of the relied upon documents. Applying the conditions for reception of additional evidence in appellate proceedings, the Tribunal held that none of the recognised grounds was established, including refusal of admissible evidence, due diligence, or any necessity for the appellate court to receive the documents to pronounce judgment or for any other substantial cause.

Conclusion: The application for permission to place additional documents on record was not maintainable and was dismissed.

Ratio Decidendi: Additional evidence at the appellate stage cannot be admitted unless the party establishes one of the legally recognised grounds, and a bare, unexplained request without showing relevance, due diligence, or substantial cause must be rejected.

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