Section 91 CrPC cannot be used for vague production requests; accused must identify documents and show relevance at trial stage.

Section 91 CrPC permits production of a document or thing only when the court finds it necessary or desirable for inquiry or trial. An accused cannot use it to seek unspecified prosecution documents or witness statements through a roving or fishing request; the material sought must be identified, its relevance disclosed, and its necessity shown for the stage of trial or cross-examination. The accused's entitlement under Section 207 is limited to materials forwarded with the police report, and fair trial considerations do not expand that statutory scheme. Vague applications lacking particulars and relevance may be summarily rejected.

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Issues: Whether the accused, at the stage of trial and cross-examination, could invoke Section 91 of the Code of Criminal Procedure, 1973 to seek production of unspecified documents and witness statements said to be in the possession of the prosecution without demonstrating their contents or relevance, and whether the trial court erred in summarily rejecting such applications.

Analysis: Section 91 of the Code of Criminal Procedure, 1973 permits production of a document or thing only when the court finds it necessary or desirable for inquiry or trial. The entitlement of an accused under the Code is not unlimited: under Section 207 of the Code of Criminal Procedure, 1973 the accused is entitled only to specified materials forwarded with the police report, and Section 91 cannot be used to demand a roving or fishing inquiry for undisclosed material to build a defence. The accused must specify the document, disclose its relevance, and show how it is necessary for the stage at which the request is made. Unspecified statements allegedly recorded during investigation, without identifying their contents or connection with the defence or with cross-examination of the witness, do not justify compulsory production. Fair trial does not dilute the statutory scheme, and the trial court was not bound to give a detailed merits ruling where the applications were vague and failed to disclose relevance.

Conclusion: The applications under Section 91 of the Code of Criminal Procedure, 1973 were rightly rejected, and the accused had no right to compel production of the unspecified documents and statements sought.

Ratio Decidendi: An accused cannot invoke Section 91 of the Code of Criminal Procedure, 1973 to compel production of unspecified documents or statements unless their nature and relevance are disclosed and the request is shown to be necessary or desirable for the stage of trial; the provision does not authorize a roving or fishing inquiry.

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