1. Not giving exhibit number is serious error and if from the evidence it is not clear that which of these documents were formally proved then it gives rise of confusion and anomaly in decisison.

2.in your case exhibiting the summon alone is not enough .At any one of the volumes of documents should have been exhibited .In absence of it I regret the appeal court would set aside the exhibit.

3. Howeevr the decisions you are talking about can be relied upon to drive home yourpoint that this is procedurel error and can be over looked.

A list of documents should be filed along with the plaint or written statement and if the parties want to file document subsequently, they have to take leave of the Court.

ii) The documents, which are marked, does not dispense with their proof.

iii) There is a difference between marking of a document and admitting the same in evidence.

iv) As held by the Supreme Court in R.V.E.Venkatachala Gounder (supra), the objection that the document which is sought to be proved is itself inadmissible in evidence can be raised even at a later stage or even in appeal or revision. When the objection relates to mode of proof alleging the same to be irregular or insufficient, the objection should be taken before the evidence is tendered and cannot be allowed to be raised at any stage subsequent to the marking of the document as an exhibit. This later objection is an objection relating to the irregularity or insufficiency.

v) In order to avoid delay in the trial of the suit, the Court can tentatively mark a document and examine its admissibility and the objection raised to it along with the pronouncement of judgment.

Vivian Bose, J. in Sangram Singh v. Election Tribunal : (AIR p.429, para 16) "16. Now a code of procedure must be regarded as such. It is procedure, something designed to facilitate justice and further its ends: not a penal enactment for punishment and penalties; not a thing designed to trip people up. Too technical a construction of sections that leaves no room for reasonable elasticity of interpretation should therefore be guarded against (provided always that justice is done to both sides) lest the very means designed for the furtherance of justice be used to frustrate it."

This if you consider as an injustice or erroneous judgement, you may vent out your grievances in the grounds of appeal.

You can attach the copies of the documents you rely upon with the memorandum of appeal.