#Section 91 CrPC

The Punjab & Haryana HC held that an accused cannot compel production of a status report submitted to the Supreme Court in another proceeding when it is not part of the case record, affirming that the right to seek documents under Section 91 Cr.P.C. arises at the defence stage, not during prosecution evidence. This ruling clarifies disclosure limits and impacts defence strategy in criminal trials.

The Gujarat High Court ruled that income-tax returns are irrelevant to establish a legally enforceable debt under Section 138 of the Negotiable Instruments Act, even when other transactional evidence exists. The judgment reinforces that documentary proof of debt must align with the statutory requirements of the NI Act, not ancillary financial records.

MP High Court mandates that trial courts must pass reasoned orders on applications for additional evidence under Section 91 CrPC. The ruling underscores that dismissing such applications without justification violates fair trial rights, particularly in dowry death cases where critical evidence like call recordings may be excluded.

Kerala High Court holds that accused may access documents listed in the final report under Section 91 Cr.P.C. even before charge framing, affirming fair trial rights under Evidence Act.

Madhya Pradesh High Court clarifies that Section 91 CrPC applications for document production can only be invoked at the defence stage, not during prosecution evidence.