Hostile witness examination under the Evidence Act requires more than adverse answers; limited leading questions may still be permitted.

Permission to cross-examine a party's own witness under the Evidence Act depends on a judicial assessment that the witness is hostile, unwilling to speak truthfully, or marked by animus; mere adverse answers are not enough. Where the calling party had no real expectation of support and only took a chance on favourable testimony, surprise alone does not justify invoking that power. The court may instead permit limited leading questions on material points and, where necessary, intervene to elicit the truth through its own questioning. General permission under the hostile-witness provision was refused, while limited leave on specific topics was left open and further examination was directed to continue.

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Issues: Whether permission could be granted under Section 154 of the Evidence Act to enable a party to cross-examine his own witness, and whether limited leave could be granted to put leading questions on particular matters.

Analysis: The power under Section 154 is a judicial discretion to be exercised to aid the discovery of truth, but it is not available merely because a witness gives an answer adverse to the case of the party calling him. The decisive consideration is whether the witness has shown such animus or unwillingness to speak the truth as to justify treating him as requiring cross-examination by the very party who called him. Where the party calling the witness had no expectation that the witness would support his case, and merely took the chance of useful answers, surprise cannot by itself found a claim to cross-examine under Section 154. The Court also recognised that, in appropriate situations, limited permission to put leading questions may be granted under Section 142, without conferring a general right of cross-examination, and that the Court may itself intervene under Section 165 if necessary to elicit the truth.

Conclusion: General permission under Section 154 was refused, but limited leave to put leading questions on material topics was left open. The witness's further examination was directed to continue accordingly.

Ratio Decidendi: Permission to cross-examine one's own witness under Section 154 of the Evidence Act depends on a judicially formed suspicion that the witness is unwilling to speak the truth or is actuated by hostile animus; mere adversity of answers is insufficient, and limited control over examination may instead be exercised through Sections 142 and 165.

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