Territorial limits on witness summons and document production under criminal procedure were strictly enforced.

Section 160 of the Code of Criminal Procedure limits compelled witness attendance to persons acquainted with the facts who reside within the investigating officer's police station or an adjoining police station; the territorial wording is mandatory, so a witness residing outside that area cannot be required to attend. Section 91 permits production of documents or things without insisting on personal appearance, because compliance may be made by causing the materials to be produced at the stated time and place. On that construction, notices demanding attendance from outside the territorial limit were invalid, and personal appearance for document production was unnecessary.

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Issues: (i) Whether witnesses residing outside the local limits of the investigating police station or adjoining police station can be compelled to attend under Section 160 of the Code of Criminal Procedure, 1973. (ii) Whether, under Section 91 of the Code of Criminal Procedure, 1973, personal attendance can be insisted upon merely for production of documents.

Issue (i): Whether witnesses residing outside the local limits of the investigating police station or adjoining police station can be compelled to attend under Section 160 of the Code of Criminal Procedure, 1973.

Analysis: Section 160 was read as limiting the power to require attendance to persons who, in addition to being acquainted with the facts and circumstances of the case, are residing within the limits of the investigating officer's own police station or any adjoining police station. The wording was treated as plain and unambiguous, and the Court declined to adopt an interpretation that would render the territorial words redundant. On that construction, a witness residing in Delhi could not be compelled to attend at Shillong under Section 160.

Conclusion: The notices issued under Section 160 were ultra vires and invalid, and the petitioners were not liable to be compelled to attend from Delhi as witnesses.

Issue (ii): Whether, under Section 91 of the Code of Criminal Procedure, 1973, personal attendance can be insisted upon merely for production of documents.

Analysis: Section 91 permits a person in possession or power of documents or things to produce them at the time and place stated in the summons or order, but it does not authorise insistence on personal attendance when production alone is required. The statutory scheme expressly allows compliance by causing the documents to be produced instead of attending personally.

Conclusion: Personal attendance of the petitioners was not necessary for production of the documents sought under Section 91.

Final Conclusion: The writ petition succeeded, the notices requiring attendance under Section 160 were quashed, and the demand for personal appearance for production of documents was held unnecessary.

Ratio Decidendi: The territorial limitation in Section 160 of the Code of Criminal Procedure, 1973 is mandatory, and a police officer cannot compel attendance of a witness who does not reside within the officer's own or adjoining police station; under Section 91, document production may be required without insisting on personal attendance.

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