Does Repeated Non-Appearance by Appellants Mandate Dismissal of Appeals for Default? — Clarification on Judicial Discretion and Procedural Finality

The Calcutta High Court has reaffirmed that repeated non-appearance by appellants, even after being granted a last opportunity, warrants dismissal of appeals for default. The judgment upholds existing precedent on procedural consequence, serving as binding authority for similar default scenarios, particularly in civil appellate matters.

 

Summary

Category Data
Case Name SA/915/1965 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 Bench
Precedent Value Binding authority within Calcutta High Court on dismissal for procedural default
Type of Law Civil Procedure
Ratio Decidendi
  • The High Court dismissed multiple second appeals due to repeated non-appearance by the parties, despite a final opportunity having been granted to argue the cases.
  • The Court stated that, under such circumstance, it has no recourse but to dismiss the matters for default.
  • This action affirms the principle that courts can dismiss appeals for non-prosecution and vacate any interim orders upon such dismissal.
  • No orders as to costs were made, and all existing interim orders were vacated with the dismissal.
Facts as Summarised by the Court
  • Several appeals by Budge Budge Amalgamated Mills Limited were listed for hearing.
  • On three consecutive dates (September 18, 2025, October 24, 2025, and October 31, 2025), none of the parties appeared.
  • The Court had previously granted a “last chance” to the appellant to argue but noted their continued absence.

Practical Impact

Category Impact
Binding On All subordinate courts within the Calcutta High Court’s jurisdiction

What’s New / What Lawyers Should Note

  • Reiterates that repeated failure to appear, even after specific warning and a final opportunity, justifies dismissal of civil appeals for default.
  • Interim orders attached to the appeal stand automatically vacated upon such dismissal.
  • No costs are necessarily imposed in such procedural dismissals, unless the Court directs otherwise.
  • Lawyers must ensure vigilant attendance after being granted a “last chance” to avoid dismissal for default.

Summary of Legal Reasoning

  • The Court recorded the non-appearance of parties on three consecutive hearing dates.
  • Explicitly referred to its prior order granting a “last chance” to the appellants to appear and argue their cases.
  • Upon continued absence, the Court stated there was no option but to dismiss the matters for default.
  • Ordered that all interim orders shall stand vacated.
  • Made no order as to costs.
  • No substantive legal issues or merits were addressed; the dismissal was purely on procedural grounds.

Arguments by the Parties

None recorded; the judgment notes that no parties appeared on any of the relevant hearing dates.

Factual Background

Several appeals filed by Budge Budge Amalgamated Mills Limited were scheduled for hearing before the Calcutta High Court. On the last three listed dates (September 18, 2025; October 24, 2025; and October 31, 2025), neither the appellants nor respondents appeared. The Court had explicitly granted a final opportunity to the appellants on October 24, 2025. Persistent non-appearance led to the dismissal.

Statutory Analysis

The judgment does not discuss or interpret any statutory provisions. The order is confined to procedural action (dismissal for default) owing to non-prosecution.

Dissenting / Concurring Opinion Summary

No concurring or dissenting opinions are present in this single-judge order.

Procedural Innovations

No new procedural requirements or guidelines were laid down. The judgment applies settled procedure regarding dismissal for default.

Alert Indicators

  • ✔ Precedent Followed – The decision affirms existing procedural precedent on dismissing matters for non-prosecution after fair opportunity.

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