Short answer. A summary is allowed. Rule 130, Section 7 lets voluminous documents, records, or accounts that cannot be examined in court without great loss of time be presented as a chart, summary, or calculation, so long as the originals remain available for the adverse party to examine or copy, and the court may still order their production.
What the law says
When the contents of documents, records, photographs, or numerous accounts are voluminous and cannot be examined in court without great loss of time, and the fact sought to be established is only the general result of the whole, the contents of such evidence may be presented in the form of a chart
Rule 130, Section 7 — Summaries. Read the full provision →
What the law says
The originals shall be available for examination or copying, or both, by the adverse party at a reasonable time and place. The court may order that they be produced in court.
Rule 130, Section 7 — Summaries. Read the full provision →
When the summary route is available
Section 7 applies where documents, records, photographs, or accounts are voluminous and cannot be examined in court without great loss of time, and where what is actually being established is only the general result of the whole — not the detail of any single entry. Financial records spanning many years, or large volumes of transaction logs, are typical examples of the kind of material this section is designed to accommodate.
The form the evidence can take
Under those conditions, the contents may be presented as a chart, summary, or calculation instead of walking through every underlying page. This avoids consuming trial time on material where the aggregate picture, not each individual document, is what matters to the case. A chart or calculation prepared for this purpose still needs to be based on records that genuinely exist and can be produced if challenged.
The originals still have to be accessible
The convenience of a summary comes with a safeguard: the originals must remain available for examination or copying by the adverse party, at a reasonable time and place, and the court retains the power to order their actual production in court. The summary does not make the underlying originals disappear from scrutiny. This preserves the adverse party's ability to check the summary's accuracy against the underlying records, even while the court itself works from the condensed version.
What this saves in practice
Without this rule, a party with thousands of pages of relevant records could face an unworkable choice: either spend enormous trial time walking the court through every page, or simply not present the evidence at all. Allowing a chart, summary, or calculation instead lets the court grasp the aggregate picture — total amounts, patterns across transactions, overall results — without sacrificing the adverse party's ability to verify the summary against the originals if they choose to.