Can a Second Appeal Be Dismissed for Default When the Appellant Fails to Appear?

The Calcutta High Court reiterates that persistent non-appearance by the appellant, despite repeated opportunities, mandates dismissal of second appeals for default. This order follows established procedure and upholds the precedent regarding consequences of parties’ inaction, reinforcing binding procedural standards for all subordinate courts in West Bengal.

 

Summary

Category Data
Case Name SA/915/1965 of BUDGE BUDGE AMALGAMATED MILLS LIMITED Vs SATYA BADI
CNR WBCHCA0002711965
Date of Registration 25-08-1964
Decision Date 31-10-2025
Disposal Nature DISMISSED FOR DEFAULT
Judgment Author HON’BLE JUSTICE SABYASACHI BHATTACHARYYA
Court Calcutta High Court
Bench Single Judge Bench
Precedent Value Binding on subordinate courts within Calcutta High Court jurisdiction for matters concerning procedural dismissal for default
Type of Law Procedural Law
Ratio Decidendi
  • After repeated absence of the appellant and no representation on multiple scheduled hearing dates, the Court found no other recourse but to dismiss the second appeals for default.
  • The Court provided a last chance to the appellant, which went unutilized.
  • Such dismissal for default is proper where parties are non-diligent, aligning with procedural obligations.
  • There was no discussion on the merits of the matter, and interim orders, if any, were vacated.
  • The dismissal was effected without an order as to costs.
Facts as Summarised by the Court
  • Neither party appeared at the time of call.
  • The appellant failed to appear on prior occasions (September 18, 2025 and October 24, 2025) despite a final opportunity given on October 24, 2025 to argue the appeals.
  • In the absence of representation today, the matters were dismissed for default.

Practical Impact

Category Impact
Binding On All subordinate courts within the Calcutta High Court’s jurisdiction
Persuasive For Other High Courts on procedural aspects of appeals

What’s New / What Lawyers Should Note

  • Reiterates that repeated non-appearance, even after specific last opportunities, will lead to dismissal of second appeals for default.
  • Emphasizes the importance of diligence and timely appearance by counsel for appellants.
  • Confirms that such dismissals may occur without any order as to costs and all interim orders stand vacated automatically.
  • Lawyers representing appellants in appellate matters should monitor hearing dates and court instructions to avoid procedural dismissal.

Summary of Legal Reasoning

  • The Court noted the absence of any appearance from either party on the scheduled date of hearing.
  • Historical non-appearance on two previous dates (September 18, 2025 and October 24, 2025) was recorded.
  • The Court highlighted that a specific last chance had been given to the appellant to argue the appeals, which was not availed.
  • Based on continued non-representation, the Court reasoned that no alternative remained but dismissal for default, following procedural norms.
  • Interim orders, if present, were expressly vacated.
  • No costs were imposed.

Arguments by the Parties

No submissions were made by either the appellant or the respondent, as none appeared for the parties at the time of hearing or on previous dates set by the Court.

Factual Background

The matters pertained to a set of second appeals filed by Budge Budge Amalgamated Mills Limited against various respondents. Despite being scheduled for hearing on multiple occasions (September 18, 2025 and October 24, 2025), neither party appeared before the Court. A final opportunity to the appellant for arguing the case was provided but not availed. On the current date, absence continued, which led the Court to dismiss all listed appeals for default.

Statutory Analysis

The judgment centers on procedural law, particularly the power of the appellate court to dismiss an appeal for default owing to parties’ non-appearance. No specific statutory provision is cited or interpreted in the judgment; the Court proceeds on established procedural principles that permit such dismissal when parties fail to prosecute their appeals.

Dissenting / Concurring Opinion Summary

No dissenting or concurring opinions were recorded or noted in the judgment.

Procedural Innovations

No new procedural rules or innovations were introduced. The Court followed existing procedure regarding dismissal for default after affording a last opportunity.

Alert Indicators

  • ✔ Precedent Followed – Affirms the power to dismiss for default as per existing procedural norms.

Leave a Reply

Your email address will not be published. Required fields are marked *

Recent Comments

No comments to show.