Court ruling8/11/2026

Supreme Court: An Operative Formal Order Does Not Extend the Deadline for Filing an Appeal

The Supreme Court of Israel struck out Shahar Raymond’s appeal in CA 4114/21 because it was filed three days late. The Court clarified that a later formal order that merely consolidates amounts already awarded is considered an “other decision” concerning enforcement and does not restart the period for filing an appeal.

Key facts

•Proceeding: CA 4114/21
•Court: Supreme Court of Israel
•Decision: September 5, 2021
•Filing delay: three days
•Costs on appeal: NIS 1,500
•The Civil Procedure Regulations, 5779–2018, were applied

Background to the Dispute

Mary Dahan filed a monetary claim against Shahar Raymond and three additional defendants, alleging that they had committed acts of fraud in an attempt to take control of her savings. The Central District Court in Lod largely granted the claim in CC 45776-12-17. Raymond and Defendant No. 2 were ordered, jointly and severally, to pay NIS 2,961,454, NIS 80,000 in court costs, and NIS 150,000 in attorneys’ fees—together with linkage differentials and interest under the terms set out in the judgment.

Why a Dispute Arose Regarding the Deadline

The principal judgment was issued on April 6, 2021, and on April 20 the Court signed a formal order—an official document setting out the amounts awarded. Raymond argued that the deadline for filing the appeal should be calculated from the date of this later document. The Supreme Court held that the formal order neither changed nor added anything to the obligations already established in the principal judgment.

The Supreme Court’s Position

Supreme Court Registrar Sarit Avdian applied the tests concerning finality of the proceedings and the relief granted. If a document issued after a judgment concerns only its enforcement, it constitutes an “other decision,” an appeal against which requires leave; however, if it changes the obligation itself, it may be considered a supplementary judgment. In this case, the formal order merely reflected the amounts previously determined, and the period for filing the appeal therefore ran from the date on which the principal judgment was served.

Electronic Service and the Delay

According to data from the Net HaMishpat system, notice of the judgment was sent to the email addresses of both of the appellant’s attorneys on April 8, 2021. The Court held that their declarations stating that the notice had not been received were general and insufficient; moreover, one of the attorneys had reviewed the judgment as early as April 6. The final day for filing the appeal was June 7, 2021, but it was filed on June 10.

Outcome of the Proceeding

The attempt to submit the appeal electronically on June 6 was not considered a lawful filing: the first document commencing a proceeding in the Supreme Court may not be filed in this manner. The error in selecting the method of filing was not recognized as a “special reason” for extending the deadline under the Civil Procedure Regulations, 5779–2018. The appeal was struck out, and Raymond was ordered to pay Mary Dahan costs of NIS 1,500.

What this means for you

An official document that merely repeats amounts established in a judgment already issued generally does not provide a new deadline for filing an appeal. Electronic notice through Net HaMishpat may constitute lawful service, and the first document in a new proceeding before the Supreme Court must be filed by a permitted method. Even a delay of one day requires proof of a special reason.

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