Dismissed

M/S Hm Records and Others v. M/S Sarangd Film Productions Pvt. Ltd.

Punjab & Haryana HC8 Apr 2026CR/1275/2026

Case brief

AI extract

What is this about?

This court dismissed a civil revision petition challenging the trial court's order allowing the plaintiff in a rendition of accounts suit to place a subsequent board resolution on record to correct an inadvertent date discrepancy in an earlier resolution.

What did the court decide?

The revision petition was dismissed; the order of the trial court allowing the placement of the board resolution subject to costs stands affirmed.

M/S Hm Records and Others Vs M/S Sarangd Film… — Company and Corporate | Punjab & Haryana HC (2026)

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CR-1275-2026 [1]

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IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

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CR-1275-2026 Date of decision: 08.04.2026 M/s HM Records and others ...Pe""oners

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Versus

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M/s Sarang Film Produc"ons Pvt. Ltd. ...Respondent

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CORAM: HON'BLE MR. JUSTICE DEEPAK GUPTA

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Present: Mr. Manan Khaterpal, Advocate for the pe""oner.

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DEEPAK GUPTA, J. (ORAL)

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The present civil revision pe""on has been filed by the defendants of Civil Suit No. 1111 of 2022 "tled M/s Sarang Film Produc"ons Pvt. Ltd. Vs. M/s HM Records & Others’ pending before learned Civil Judge (Junior Division), SAS Nagar (Mohali), assailing the order dated 08.08.2025 (Annexure P-10) passed by trial court, whereby the applica"on filed by the plain"ff for placing on record Board Resolu"on dated 09.12.2024 has been allowed subject to payment of costs of ₹1,000/-.

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The brief facts necessary for adjudica"on of the present pe""on are that the plain"ff has ins"tuted a suit for rendi"on of accounts on the basis of a Memorandum of Understanding. During the pendency of the suit, the plain"ff moved an applica"on seeking permission to place on record a subsequent Board Resolu"on dated 09.12.2024, sta"ng that in the earlier resolu"on dated 12.09.2022, the date of the Memorandum of Understanding executed between the par"es had been inadvertently men"oned as 18.12.2018 instead of 15.12.2018.

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The said applica"on was opposed by the defendants primarily

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YOGESH MEHTA 2026.04.09 14:32 I attest to the accuracy and integrity of this document

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CR-1275-2026 [2]

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on the ground that the plain"ff had earlier declined to produce documents despite opportunity having been granted and, therefore, was estopped from placing any further documents on record. It was further contended that the defect in authoriza"on was not a mere irregularity but went to the root of the maIer, and that the trial Court, by allowing the applica"on, had in effect reviewed its earlier order dated 25.01.2024.

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The learned trial Court, aJer considering the rival submissions, came to the conclusion that the resolu"on sought to be placed on record was only clarificatory in nature and intended to correct an inadvertent error in the earlier resolu"on. It was further observed that the suit was at an ini"al stage and the defendants would have adequate opportunity to meet the case of the plain"ff. Accordingly, the applica"on was allowed subject to costs.

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Assailing the above order, Learned counsel for the pe""oners has reiterated before this Court that the impugned order suffers from material irregularity and amounts to permiKng the plain"ff to fill lacunae in its case. It is further argued that once the plain"ff had been specifically restrained from producing documents at a later stage, the trial Court could not have permiIed the present document to be taken on record.

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Having heard learned counsel for the pe""oners and perused the record, this Court does not find any merit in the present revision pe""on.

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It is trite that the revisional jurisdic"on of this Court is confined

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YOGESH MEHTA 2026.04.09 14:32 I attest to the accuracy and integrity of this document

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CR-1275-2026 [3]

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to examining the legality and propriety of the order impugned and does not extend to re-apprecia"on of facts or subs"tu"on of discre"on exercised by the trial Court, unless the same is shown to be perverse or suffering from jurisdic"onal error.

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In the present case, the document sought to be produced is a subsequent Board Resolu"on passed to rec"fy an inadvertent mistake in the earlier resolu"on with regard to the date of the Memorandum of Understanding. The plaint itself, as no"ced by the learned trial Court, consistently refers to the correct date of the Memorandum of Understanding and the discrepancy is confined only to the authoriza"on resolu"on. Thus, the nature of the document is essen"ally clarificatory.

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The conten"on of the pe""oners that the trial Court has reviewed its earlier order dated 25.01.2024 is misconceived. The earlier order merely restricted the plain"ff from producing documents, which were in existence and were consciously withheld. The present resolu"on, however, is a subsequent document brought into existence to cure a defect and cannot be equated with documents which were earlier withheld.

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It is equally well seIled that procedural rules are intended to advance the cause of jus"ce and not to thwart it. Unless serious prejudice is shown to have been caused, a party ought not to be non-suited on account of curable defects, par"cularly when the proceedings are s"ll at a nascent stage. In the present case, no irreparable prejudice is shown to be caused to the defendants, who would have full opportunity to contest the claim of the plain"ff on merits.

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YOGESH MEHTA 2026.04.09 14:32 I attest to the accuracy and integrity of this document

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CR-1275-2026 [4]

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The learned trial Court has exercised its discre"on judiciously and has also safeguarded the interest of the defendants by imposing costs. No jurisdic"onal error, illegality or material irregularity has been pointed out which may warrant interference by this Court in exercise of its revisional jurisdic"on.

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Consequently, finding no merit in the present revision pe""on, the same is hereby dismissed.

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Pending applica"ons, if any, shall also stand disposed of.

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08.04.2026 (DEEPAK GUPTA) Yogesh JUDGE

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Yogesh

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Whether speaking/reasoned:Yes/No Whether reportable:Yes/No

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YOGESH MEHTA 2026.04.09 14:32 I attest to the accuracy and integrity of this document

M/S Hm Records and Others v. M/S Sarangd Film Productions Pvt. Ltd.

Case brief

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M/S Hm Records and Others v. M/S Sarangd Film Productions Pvt. Ltd.

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