A foundational principle of civil litigation is that a court can only consider evidence and grant reliefs that are based on clear and specific statements made in the pleadings.
The Supreme Court has repeatedly affirmed that any evidence led or relief sought beyond the scope of the pleadings is inadmissible.
The Supreme Court’s Consistent Stance
The Supreme Court’s position on this rule is unwavering:
In Bachhaj Nahar v. Nilima Mandal & Ors. [AIR 2009 SC 1103], the Court held that the relief granted in a civil suit depends entirely on the pleadings and the evidence led in support of them.
This was reiterated in State of Uttarakhand v. Mandir Sri Laxman Sidh Maharaj (2017), where the Court emphasized that it “cannot travel beyond the pleadings” when granting relief.
The consequence of failing to plead was starkly illustrated inBiraji @ Brijraji & Another. v. Surya Pratap & Ors [AIR Online 2020 SC 806]. The Court observed that if pleadings are absent, “any amount of evidence submitted later, will not be taken into consideration,” quoting the settled principle that “in absence of pleadings… any amount of evidence will not help the party.”
Most recently, in Manjudha & Others v United India Assurance Company Ltd. & Another [2025 INSC 896], the Court described pleadings and their proof as the “crux and core of any adjudicatory process,” calling it a trite principle that “there can be no proof offered without specific pleadings.”
Conclusion: Pleadings as the Bedrock of a Case
In essence, pleadings form the bedrock of a civil case. Without a fact being explicitly pleaded, a party cannot lead evidence on that fact, make arguments based on it, or seek any relief flowing from it. This ensures that the litigation is structured, the opposing party has fair notice of the case they have to meet, and the court’s adjudication is confined to the specific dispute brought before it.
