This article is written by Rajalakshmi Ganesan, Renaissance University, LLB, 3rd year during her internship at LeDroit India
Keywords
Admissions, Order 12 Rule 6, Civil Procedure Code, Judgment on Admissions, Judicial Discretion, Case Laws, Procedural Efficiency, Litigation Strategy.
Scope of Article
- Introduction to Judgment on Admissions
- Historical Development of Order 12 Rule 6 CPC
- Statutory Framework and Interpretation
- Principles Governing Judgment on Admissions
- Judicial Discretion and Limits
- Landmark Case Laws (Supreme Court & High Courts)
- Practical Applications and Illustrations
- Comparative Perspective (International Practices)
- Conclusion
Abstract
Order 12 Rule 6 of the Code of Civil Procedure, 1908 (CPC) empowers courts to pronounce judgment based on admissions made by parties, thereby avoiding the need for a full trial. This provision serves as a tool of judicial economy, ensuring that litigation does not become unnecessarily prolonged when material facts are undisputed. Admissions may arise in pleadings, documents, or statements made during proceedings, and once established, they provide a sufficient foundation for judgment. Courts, however, exercise discretion carefully, ensuring that admissions are clear, unambiguous, and unequivocal before granting relief.
The doctrine has been shaped by significant precedents. In Uttam Singh Duggal v. Union of India (2000), the Supreme Court emphasized that the rule is intended to give litigants speedy justice where admissions leave no room for doubt. Similarly, in Karam Kapahi v. Lal Chand Public Charitable Trust (2010), the Court clarified that admissions can be inferred from conduct and documents, not merely pleadings. This article explores the historical evolution, statutory framework, and judicial interpretation of Order 12 Rule 6, highlighting its role in promoting efficiency, reducing backlog, and safeguarding fairness. Comparative perspectives show how similar mechanisms operate in other jurisdictions, reinforcing its importance in modern civil procedure.
Introduction
Civil litigation in India is often criticized for delays, procedural complexity, and the burden of evidence. Recognizing this, the CPC provides mechanisms to streamline adjudication. One such mechanism is Order 12 Rule 6, which allows courts to deliver judgment on the basis of admissions without requiring a full trial. This provision reflects the principle that where facts are undisputed, justice should not be delayed by unnecessary formalities.
Admissions serve as a shortcut to truth. They are concessions made by parties that eliminate the need for proof. By enabling courts to act upon such admissions, Order 12 Rule 6 transforms litigation strategy: it allows decree-holders to secure relief swiftly, while preventing defendants from prolonging proceedings through frivolous denials. Yet, the provision is not absolute. Courts must ensure that admissions are clear, unambiguous, and substantive before pronouncing judgment.
This article examines the jurisprudence of Order 12 Rule 6, tracing its historical development, statutory framework, and judicial interpretation. It explores landmark cases, practical applications, and comparative perspectives, ultimately assessing how the rule balances efficiency with fairness in civil procedure.
Historical Development of Order 12 Rule 6
Colonial Foundations (Pre-1947)
The Code of Civil Procedure, 1908 (CPC) marked a significant consolidation of procedural law in India, drawing extensively from English civil procedure to ensure uniformity and predictability in litigation. One of the principles borrowed from English practice was the recognition that admissions, when clear and unequivocal, could serve as the foundation for judgment without the need for a full trial. English courts had long emphasized that such admissions promoted equity and efficiency, as they eliminated unnecessary disputes over facts that were already conceded. This approach reflected a broader philosophy of judicial economy, ensuring that courts did not expend time and resources on issues that were no longer in contention. In India, however, the early High Courts approached the doctrine with caution. They treated judgments on admissions as an exceptional remedy, mindful of the fact that litigants should not be deprived of their right to a trial unless the admissions were explicit, unconditional, and left no scope for ambiguity. This careful balance between efficiency and fairness laid the groundwork for the later evolution of Order 12 Rule 6, where courts continued to insist that only clear and substantive admissions could justify bypassing the trial process.
Post-Independence Evolution (1950s–1970s)
After independence, the Supreme Court of India began to shape the jurisprudence surrounding admissions in line with constitutional values, ensuring that procedural shortcuts did not undermine fairness or equity. The Court emphasized that while Order 12 Rule 6 was designed to promote efficiency, its application had to remain consistent with the broader principles of justice enshrined in the Constitution. In Moti Lal v. State of U.P. (1951), the Supreme Court made it clear that discretionary relief under this provision must always align with equity, cautioning that admissions should not be misused as tools to delay proceedings or deprive parties of substantive justice. This case set the tone for a careful and restrained approach, reminding courts that admissions must be substantive and unequivocal before they could form the basis of judgment. Building on this foundation, High Courts in the 1960s and 1970s increasingly recognized the evidentiary value of admissions in pleadings and documents, but they consistently insisted on clarity and certainty. Courts refused to act on vague or qualified admissions, reinforcing the principle that only clear concessions of fact could justify bypassing a full trial. This period marked the gradual evolution of admissions jurisprudence into a doctrine balancing efficiency with fairness.
Codification & Refinement (1980s–2000s)
During the period of codification and refinement, amendments to the Code of Civil Procedure brought greater clarity to the scope of admissions, making it explicit that they could arise not only in pleadings but also in documents, correspondence, and other forms of communication between parties. This broadened understanding ensured that courts were not confined to admissions made in formal pleadings alone but could also rely on clear concessions evident in written exchanges or contractual records. The landmark case of Uttam Singh Duggal v. Union of India (2000) further transformed the application of Order 12 Rule 6 into a calibrated remedy. The Supreme Court emphasized that the provision was intended to deliver speedy justice in situations where admissions left no room for doubt, thereby preventing unnecessary trials and saving judicial time. This judgment underscored that Rule 6 was not a mere procedural shortcut but a substantive tool to uphold fairness and efficiency. Consequently, this period marked a significant shift in judicial thinking: admissions were no longer treated as incidental or peripheral but recognized as substantive grounds for judgment. Courts increasingly viewed them as a reliable foundation for decrees, provided they were clear, unambiguous, and unequivocal.
Contemporary Phase (2010s–2020s)
In Karam Kapahi v. Lal Chand Public Charitable Trust (2010), the Supreme Court significantly broadened the scope of admissions under Order 12 Rule 6 by recognizing that they could arise not only from pleadings but also from the conduct of parties and documentary evidence. This marked a doctrinal shift, as courts were no longer confined to admissions made in formal pleadings but could also rely on clear concessions evident in contracts, correspondence, or behavior during litigation. Building on this precedent, recent rulings have emphasized that while Rule 6 is a powerful tool for promoting efficiency and reducing unnecessary trials, its application must be guarded against misuse. Courts have consistently reiterated that admissions must be substantive, unequivocal, and unambiguous, cautioning that casual remarks or inferential statements cannot form the basis of a decree. This careful approach ensures that the provision is not exploited to deprive parties of their right to contest genuine disputes. At the same time, with India’s rising case backlogs, courts have increasingly turned to Rule 6 as a mechanism to reduce delays, particularly in commercial suits and tenancy disputes where admitted facts often leave little room for controversy. Thus, the contemporary phase reflects both expansion and restraint, balancing efficiency with fairness.
Statutory Framework and Interpretation
Order 12 Rule 6 of the Code of Civil Procedure is a distinctive provision that empowers courts to pronounce judgment solely based on admissions made by the parties. The language of the rule is deliberately broad, allowing admissions to be considered whether they are contained in pleadings, made orally during proceedings, or evidenced through written documents. This breadth ensures that the court is not restricted to formal pleadings alone but can consider any clear concession of fact that emerges during litigation. Importantly, the rule authorizes the court to act “at any stage of the suit,” which means that a judgment can be delivered even before the trial commences, thereby saving valuable judicial time and resources.
The provision also underscores the discretionary nature of the court’s power. While the court may pronounce judgment on admissions, it is not bound to do so in every case. Judges must carefully assess whether the admissions are clear, unambiguous, and unconditional. If the admissions are vague, qualified, or leave room for interpretation, the court may decline to exercise its power under Rule 6, ensuring that no party is unfairly deprived of the opportunity to contest genuine issues. The underlying objective of the rule is to prevent unnecessary trials where facts are undisputed, thereby promoting efficiency without compromising fairness.
Judicial interpretation has consistently reinforced that admissions under Rule 6 must be substantive and unequivocal. Casual remarks, inferential statements, or partial concessions cannot form the basis of a decree. Moreover, the relief granted must correspond precisely to the scope of the admission, ensuring that courts do not extend judgments beyond what has been conceded. In this way, Order 12 Rule 6 harmonizes the twin goals of civil procedure: expediting justice where disputes are illusory, while safeguarding the integrity of adjudication where genuine controversies remain.
Key features:
The key features of Order 12 Rule 6 highlight both its breadth and its careful balance between efficiency and fairness.
First, the rule makes it clear that admissions are not confined to formal pleadings alone. They may also be found in oral statements made during proceedings, in documentary evidence, or even in the conduct of the parties. This expansive scope ensures that courts can act upon any clear concession of fact, regardless of the form in which it appears.
Second, the provision allows judgment to be pronounced at any stage of the suit, meaning that courts are not required to wait until trial begins or evidence is fully led. This flexibility enables the judiciary to deliver swift relief where disputes are illusory. At the same time, the rule underscores that the power to pronounce judgment is discretionary.
Courts are not bound to act on every admission; they may refuse to do so if the admission is vague, qualified, or leaves room for doubt. This discretion protects litigants from being unfairly deprived of their right to contest genuine issues. Finally, the overarching objective of the rule is to prevent unnecessary trials where facts are undisputed, thereby conserving judicial resources while ensuring that justice is not delayed by needless formalities.
Interpretation:
Here is the interpretation of Order 12 Rule 6 CPC presented clearly in points:
- Admissions must be clear, unambiguous, and unconditional; only such admissions can form the basis of a decree.
- Courts cannot rely on casual remarks, vague statements, or inferential admissions to pronounce judgment.
- Relief granted must correspond exactly to the scope of the admission, ensuring that courts do not extend decrees beyond what has been expressly conceded.
- Judicial discretion remains central — courts may refuse judgment if the admission leaves room for doubt or requires further clarification.
- The provision is designed to prevent unnecessary trials where facts are undisputed, thereby conserving judicial time and resources.
Principles Governing Judgment on Admissions
The principles governing judgment on admissions under Order 12 Rule 6 are rooted in equity and share a close resemblance to the jurisprudence surrounding injunctions. Courts have consistently emphasized that before pronouncing judgment on the basis of admissions, they must be satisfied that a prima facie case exists. This means that the admissions relied upon must establish a clear entitlement to relief, leaving no room for ambiguity or doubt. If the admissions are partial, qualified, or open to interpretation, the court will refrain from granting judgment, as doing so could compromise substantive justice.
Equally important is the principle of the balance of convenience. Courts must weigh the comparative harm that may result from granting or refusing judgment on admissions. The rule is not intended to prejudice substantive rights; rather, it is designed to prevent unnecessary trials where disputes are illusory. Thus, if acting on admissions would unfairly deprive a party of the opportunity to contest genuine issues, courts will exercise restraint.
The principle of irreparable injury also plays a role. If clear admissions are ignored, parties may suffer unnecessary delay, expense, and prolonged litigation. This undermines the very purpose of Rule 6, which is to expedite justice where facts are undisputed. By acting on admissions, courts protect litigants from the hardship of needless trials and ensure that justice is not delayed by procedural formalities.
Finally, courts emphasize judicial restraint in applying Rule 6. While the provision is a powerful tool for efficiency, it must not be misused as a shortcut to bypass genuine disputes. Judges are careful to ensure that admissions are substantive and unequivocal, discouraging litigants from attempting to exploit the rule for tactical advantage. In this way, Rule 6 harmonizes speed with fairness, allowing courts to deliver swift relief where disputes are illusory while safeguarding the integrity of adjudication where real controversies remain.
Judicial Discretion and Limits
Judgment on admissions under Order 12 Rule 6 is not an automatic entitlement for the parties; rather, it is a matter of judicial discretion. The courts retain the authority to determine whether the admissions presented are sufficiently clear and substantive to justify a decree without trial. This discretionary nature ensures that the provision is not misapplied or exploited as a shortcut to justice. In practice, courts often impose conditions to safeguard fairness. For instance, they may limit relief strictly to the facts that have been expressly admitted, thereby preventing any extension of judgment into areas where disputes still exist. Similarly, if the admissions are qualified, partial, or leave room for ambiguity, courts may refuse to pronounce judgment altogether, recognizing that such concessions do not provide a reliable foundation for a decree.
Another important safeguard lies in the court’s willingness to allow a trial to proceed on issues that remain contested, even while granting judgment on admitted facts. This calibrated approach ensures that Rule 6 is applied only to streamline litigation where disputes are illusory, while preserving the right to trial on genuine controversies. By balancing efficiency with fairness, courts prevent misuse of the provision and uphold the principle that justice must not only be swift but also equitable. In this way, judicial discretion acts as a protective mechanism, ensuring that Order 12 Rule 6 serves its intended purpose of expediting justice without depriving parties of their substantive rights.
Landmark Case Laws
- Uttam Singh Duggal v. Union of India (2000)
Principle:
In this landmark case, the Supreme Court clarified the true purpose of Order 12 Rule 6 CPC. The Court held that the provision was designed to ensure speedy justice in situations where admissions are so clear and unequivocal that they leave no scope for further controversy. The judgment emphasized that Rule 6 is not a mere procedural shortcut but a substantive tool to prevent unnecessary trials. The Court explained that once a party has made a substantive admission of fact, the other side should not be compelled to undergo the rigors of a full trial, as this would amount to a waste of judicial time and resources. At the same time, the Court drew a sharp distinction between genuine admissions and casual or vague statements. It stressed that only clear, unambiguous, and unconditional admissions could justify a decree under Rule 6, while qualified or inferential concessions could not. This principle established a doctrinal safeguard, ensuring that the provision would be applied only in cases where the admitted facts were sufficient to grant relief without prejudice to the parties.
Impact:
The ruling in Uttam Singh Duggal transformed the way courts approached Rule 6. Before this case, judgments on admissions were treated cautiously and applied sparingly. After this decision, Rule 6 was recognized as a calibrated remedy that could be confidently invoked to streamline litigation. The Court’s insistence on substantive admissions provided a clear standard for judges, preventing misuse of the provision by litigants attempting to rely on incomplete or ambiguous statements. The impact was twofold: it encouraged courts to use Rule 6 more proactively to reduce delays, while simultaneously safeguarding fairness by ensuring that only unequivocal admissions could form the basis of a decree. This case thus stands as a cornerstone in the jurisprudence of admissions, guiding courts to balance judicial economy with equitable justice, and remains one of the most frequently cited authorities on the subject.
- Karam Kapahi v. Lal Chand Public Charitable Trust (2010)
Principle:
In this important decision, the Supreme Court broadened the interpretative horizon of Order 12 Rule 6 CPC. The Court held that admissions need not be confined strictly to pleadings filed before the court; they could also be inferred from the conduct of the parties and from documentary evidence produced during litigation. This meant that even if a party did not expressly concede a fact in its written statement, its actions, contractual documents, or correspondence could amount to an admission if they clearly reflected acknowledgment of the disputed fact. The ruling underscored that admissions are not limited to formal pleadings but may arise in any form that demonstrates a party’s acceptance of a material fact. By recognizing conduct and documents as valid sources of admission, the Court reinforced the principle that substance must prevail over form, ensuring that justice is not delayed by technicalities.
Impact:
The impact of this ruling was significant, as it expanded the scope of Rule 6 beyond pleadings and gave courts greater flexibility in identifying admissions. This expansion allowed judges to rely on a wider range of evidence to pronounce judgment, thereby reducing the possibility of parties evading responsibility through carefully crafted pleadings that avoided explicit admissions. The decision empowered courts to cut through procedural maneuvering and focus on the real substance of disputes. As a result, Rule 6 became a more effective tool in expediting litigation, particularly in commercial and tenancy matters where documentary evidence often reveals clear concessions. The case thus marked a turning point in admissions jurisprudence, ensuring that courts could act decisively on admissions wherever they appeared, whether in pleadings, documents, or conduct, thereby strengthening the efficiency and fairness of civil procedure.
- Jeevan Diesels & Electricals Ltd. v. Jasbir Singh Chadha (2010)
Principle:
In this case, the Supreme Court reiterated that for a judgment to be pronounced under Order 12 Rule 6 CPC, the admissions relied upon must be unequivocal, clear, and unconditional. The Court stressed that any admission which is qualified, ambiguous, or open to interpretation cannot serve as the foundation for a decree. This principle reinforced the idea that Rule 6 is not meant to be applied mechanically; rather, it requires careful judicial scrutiny to ensure that the admission truly leaves no scope for doubt or controversy. By insisting on unequivocal admissions, the Court safeguarded the rights of litigants, ensuring that no party is deprived of a trial where genuine disputes remain.
Impact:
The impact of this ruling was to reinforce judicial caution in the application of Rule 6. While earlier decisions had expanded the scope of admissions to include documents and conduct, Jeevan Diesels reminded courts that the threshold for acting on admissions must remain high. Judges were cautioned against treating casual remarks or partial concessions as sufficient grounds for judgment. This case thus served as a doctrinal counterbalance, ensuring that the efficiency promoted by Rule 6 did not come at the cost of fairness. It strengthened the principle that Rule 6 is a discretionary remedy, to be applied only when admissions are so clear and unconditional that they leave no room for genuine dispute.
- High Court Rulings
Delhi High Court:
The Delhi High Court has consistently held that admissions made in tenancy disputes are sufficient to justify a decree under Order 12 Rule 6 CPC. The Court reasoned that where a tenant unequivocally admits the existence of the tenancy and the relationship with the landlord, there is no need to prolong the litigation through a full trial. Such admissions, being clear and substantive, provide a firm foundation for granting relief, particularly in suits for possession and recovery of rent. This approach reflects the Court’s commitment to efficiency in resolving tenancy matters, where disputes often hinge on admitted facts rather than contested issues.
Bombay High Court:
The Bombay High Court has expanded the application of Rule 6 in the context of commercial disputes, holding that admissions contained in correspondence between parties can be sufficient to enforce contractual obligations. The Court emphasized that business communications, letters, and exchanges often reveal clear concessions of liability or acknowledgment of terms, which can amount to admissions under the rule. By recognizing correspondence as a valid source of admission, the Court ensured that commercial contracts could be enforced swiftly without unnecessary trials, thereby promoting certainty and efficiency in business litigation. This ruling reinforced the principle that substance must prevail over form, allowing courts to act decisively on admissions wherever they appear.
Practical Applications and Illustrations
- Commercial Contracts: In the realm of commercial litigation, Order 12 Rule 6 CPC has proven to be a valuable tool for expediting justice. Business dealings often generate extensive correspondence, including letters, emails, and contractual documents, which may contain clear acknowledgments of liability or acceptance of terms. When such admissions are evident, courts can pronounce judgment without requiring a full trial. This approach prevents parties from prolonging disputes through technical defenses or evasive pleadings. By acting on admissions in correspondence, courts ensure that commercial contracts are enforced swiftly, thereby promoting certainty in business transactions and reducing the burden of lengthy litigation.
- Tenancy Disputes: Tenancy matters frequently involve straightforward issues such as the existence of a landlord-tenant relationship and the payment of rent. Where tenants admit arrears of rent or acknowledge the tenancy, courts have consistently held that such admissions are sufficient to justify a decree under Rule 6. This allows landlords to secure possession or recover arrears without unnecessary delay. The Delhi High Court has emphasized that once the tenant admits the tenancy and default, there is no need for a prolonged trial. This application of Rule 6 ensures efficiency in tenancy disputes, which are otherwise prone to protracted litigation, and provides landlords with timely relief.
- Family Property Cases: In partition suits and family property disputes, admissions often play a crucial role in narrowing the scope of controversy. Parties may concede certain relationships, shares, or ownership interests, even while contesting other aspects of the claim. Courts can act on these admissions to deliver partial judgments, thereby settling undisputed portions of the dispute while allowing trial to proceed on contested issues. This calibrated use of Rule 6 reduces the complexity of partition suits, ensures that admitted rights are recognized without delay, and streamlines the trial by focusing only on genuine disputes. In this way, Rule 6 serves both efficiency and fairness in family property cases, balancing the need for speedy justice with the protection of substantive rights.
Illustrations:
- Tenant Admitting Arrears of Rent:
Consider a tenancy dispute where the tenant, in their written statement, expressly admits that rent arrears are due and payable to the landlord. Since the existence of the tenancy and the default in payment are conceded, the court need not proceed with a full trial to establish these facts. Acting under Order 12 Rule 6 CPC, the court can immediately pronounce a decree for recovery of rent or possession, thereby saving time and resources. This illustration demonstrates how Rule 6 streamlines litigation in tenancy matters, ensuring landlords are not forced into prolonged proceedings when the tenant’s own admission has already resolved the core issue.
- Company Admitting Liability in Correspondence:
In commercial disputes, correspondence between parties often reveals clear acknowledgments of liability. For instance, if a company, through letters or emails, admits that it owes a certain sum under a contract, such communication can be treated as an admission under Rule 6. The court, relying on this documentary evidence, may enforce the contract and pronounce judgment without requiring a trial. This application is particularly valuable in business litigation, where parties sometimes attempt to delay proceedings despite having conceded liability in writing. By acting on admissions in correspondence, courts uphold efficiency and certainty in commercial transactions, ensuring that admitted obligations are enforced swiftly.
Comparative Perspective
- United Kingdom:
In the United Kingdom, the Civil Procedure Rules (CPR) provide for summary judgment, a mechanism that allows courts to pronounce judgment where a party has “no real prospect of success” in defending or pursuing a claim. This provision is broader than India’s Order 12 Rule 6, as it does not rely solely on admissions but encompasses situations where the evidence clearly demonstrates that a trial would serve no purpose. The English courts emphasize efficiency and judicial economy, ensuring that cases without genuine disputes are disposed of swiftly. The philosophy here is pragmatic: litigation should not proceed where the outcome is obvious, and summary judgment serves as a filter to prevent unnecessary trials
- United States:
In the United States, Rule 56 of the Federal Rules of Civil Procedure governs summary judgment. This rule allows courts to grant judgment where there is no genuine dispute of material fact, often relying on admissions, depositions, affidavits, and documentary evidence. The American approach is highly evidence-driven, requiring parties to demonstrate that the facts are either undisputed or admitted, leaving only questions of law for the court to decide. Rule 56 is widely used in civil litigation, particularly in commercial and contractual disputes, as it enables courts to avoid lengthy trials when the factual foundation of the case is already conceded. The emphasis is on ensuring that judicial resources are reserved for genuine controversies, while admitted or undisputed facts are resolved through summary judgment.
- India:
India’s Order 12 Rule 6 CPC represents a more calibrated blend of efficiency and discretion. Unlike the UK and US systems, which allow summary judgment on broader grounds, the Indian provision is narrower, focusing specifically on admissions of fact made in pleadings, documents, correspondence, or conduct. The rule empowers courts to pronounce judgment at any stage of the suit, but only where admissions are clear, unambiguous, and unconditional. Importantly, the discretionary nature of Rule 6 ensures that courts retain the power to refuse judgment if the admissions are vague or qualified, thereby safeguarding fairness. This balance reflects India’s judicial philosophy: while efficiency is necessary to reduce case backlogs, fairness must not be compromised. As a result, Rule 6 has become a vital tool in expediting litigation, particularly in tenancy and commercial disputes, while maintaining judicial restraint to prevent misuse.
Conclusion
Order 12 Rule 6 of the Code of Civil Procedure stands as a cornerstone of judicial efficiency, embodying the principle that justice should not be delayed where facts are undisputed. By empowering courts to pronounce judgment on admissions, the provision serves multiple purposes: it reduces the mounting backlog of cases, prevents litigants from abusing procedural technicalities, and ensures that fairness is upheld by sparing parties the burden of unnecessary trials. In this way, Rule 6 reflects the judiciary’s commitment to balancing speed with equity.
Over the years, landmark precedents have clarified the contours of this provision, emphasizing that only clear, unambiguous, and unconditional admissions can form the basis of a decree. Courts have reinforced that discretion must be exercised judiciously, ensuring that Rule 6 is not misused as a shortcut to bypass genuine disputes. This careful calibration has transformed the rule into a reliable instrument of justice, one that streamlines litigation without compromising the substantive rights of the parties.
As litigation in India grows increasingly complex—spanning commercial contracts, tenancy disputes, and family property suits—the relevance of Rule 6 has only deepened. It provides a mechanism for courts to act decisively where disputes are illusory, while preserving the sanctity of trial where controversies remain real. In comparative perspective, India’s approach blends efficiency with restraint, harmonizing the need for swift justice with the enduring values of fairness and due process.
Ultimately, Order 12 Rule 6 CPC is more than a procedural device; it is a judicial philosophy in action. It symbolizes the courts’ resolve to deliver justice not only in substance but also in time, ensuring that the maxim justice delayed is justice denied does not become a reality. By harmonizing speed with justice, the provision continues to play a vital role in strengthening the civil justice system and reaffirming public confidence in the rule of law
