You can't ask anything in court. Here's the test.
Rajasthan HC says interrogatories must have a direct link to the dispute—not be a fishing expedition.
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rule.
Rajasthan HC says interrogatories must have a direct link to the dispute—not be a fishing expedition.
A party wanted to ask the other side everything. The court stopped it with one rule. In a dispute before the Rajasthan High Court, one side—Govind Narayan and others—had prepared a list of interrogatories for the other, Nagendra Nagda and others. The list was long, covering ground that seemed to stretch far beyond the actual fight. The other side objected. The matter reached the High Court for a ruling on the boundaries of this tool.
When the questions arrived
The case was Govind Narayan and Ors. v. Nagendra Nagda and Ors. The dispute itself was not the headline. What caught attention was the procedural weapon one party tried to use: interrogatories—written questions that one party sends to the other before trial, requiring sworn answers. Think of them as a legal cross-examination in advance, but only for specific, permitted purposes.
In a lawyer's office, the faint smell of ink and paper hung in the air. The party seeking answers had drafted a long list of interrogatories, each question typed neatly on a sheet. The other side pushed back, arguing that the questions went far beyond what the law allows. The trial court had to decide. The matter eventually reached the Rajasthan High Court for a ruling on the boundaries of this tool.
The legal framework: Section 30 and Order XI Rule 1
The court examined two provisions working together. Section 30 of the Code of Civil Procedure, 1908 gives courts broad discretion to order interrogatories at any stage of a case. Order XI Rule 1 lays down the procedure—how interrogatories must be served, answered, and objected to. Together, they create a system meant to streamline litigation, not to turn it into a fishing expedition.
The key question was: what limits exist on this discretion? Can a court allow any question, as long as it is asked in writing? Or must the questions serve a specific purpose tied to the dispute itself?
In the courtroom, the judge sat in silence, reading through the list of interrogatories. The pages rustled as he turned them. The lawyer for Govind Narayan watched, waiting for a sign. The judge's face gave nothing away.
Why the court stopped the questions
The Rajasthan High Court made its position clear. While Section 30 grants wide discretion, that discretion must be exercised "judiciously"—meaning with reason, not as a blank cheque. The court laid down the central test: "The information asked under interrogatories shall have nexus with the dispute in question."
This is not a minor procedural point. It is the gatekeeper. If the interrogatory does not have a direct link to the actual dispute between the parties, it fails. The court reasoned that the entire purpose of interrogatories is to "save time and cost by encompassing the issues or narrowing down the disputes." If a question does not help narrow the issues or reduce the scope of the trial, it becomes something else entirely—a roving enquiry (a broad, unfocused search for information without a clear connection to the dispute), which the law does not permit.
Consider a hypothetical example. In a dispute over a broken contract for the sale of goods, a proper interrogatory might be: "Did you receive the goods on the agreed date?" That question has a direct nexus to the dispute. An improper interrogatory would be: "List all your business dealings in the last five years." That question has no direct link to the dispute. It is a roving enquiry. The court's ruling makes this distinction clear.
The difference between narrowing and fishing
This distinction matters. A roving enquiry is exactly what interrogatories are meant to prevent, not enable. The tool exists to make litigation faster and cheaper by forcing parties to reveal key facts early. But if a party uses interrogatories to ask about everything under the sun—hoping something useful turns up—that defeats the purpose. It wastes time, increases costs, and burdens the other side with answering questions that have no bearing on the case.
The court's ruling draws a bright line: the interrogatory must have a direct nexus to the dispute. If it does not, the court must disallow it, regardless of how wide the court's discretion might seem on paper.
In the High Court, the lawyer for Nagendra Nagda held the heavy legal file in his hands. He argued that the interrogatories were not a legitimate attempt to narrow the issues but a fishing expedition. The court agreed. The weight of the file felt like the weight of the case itself—too much, too broad, too unfocused.
What this means for practitioners
For lawyers drafting interrogatories, this judgment is a warning. Every question must be justified by its connection to the specific issues in the case. A party cannot use interrogatories as a discovery tool to explore every possible angle. The question must serve the purpose of narrowing the dispute or saving time and cost—not expanding the battlefield.
For the party receiving interrogatories, this ruling provides a clear ground for objection. If a question lacks a direct nexus to the dispute, it can and should be challenged. The court will not allow a party to turn interrogatories into a fishing expedition.
The parties' arguments were clear. Govind Narayan's side wanted broad answers, hoping to find something useful. Nagendra Nagda's side wanted strict limits, arguing that the questions were an abuse of process. The High Court sided with the latter, reinforcing the narrow purpose of interrogatories.
THE PLAY: Before serving interrogatories, ask yourself: does this question have a direct link to the dispute, or am I just hoping something turns up? If it is the latter, the court will strike it down.
The court ended where it began. One rule. That is all it takes to separate legitimate questioning from a roving enquiry. The judge's silence, the rustle of paper, the weight of the file—all of it pointed to the same conclusion: interrogatories are a scalpel, not a sledgehammer.