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Issues: Whether documents could be summoned under Section 91 of the Code of Criminal Procedure, 1973 for the purpose of cross-examination of a prosecution witness, and whether the application disclosed sufficient necessity or relevance for such production.
Analysis: Section 91 permits production of documents or things only when the Court is satisfied that they are necessary or desirable for investigation, inquiry, trial or other proceedings. The power is discretionary and must be exercised with reference to the stage of the proceedings and the specific purpose for which the documents are sought. A blanket or roving request for a large mass of records, without demonstrating concrete relevance to the witness's testimony or to the just decision of the case, does not satisfy the statutory test. The request in this case sought multiple records touching the witness's official and personal movements, visitor registers, meeting details and call records, but did not establish a focused nexus with the proposed cross-examination.
Conclusion: The documents were not shown to be necessary or desirable for cross-examination, and the refusal to summon them was justified. The petition failed.
Final Conclusion: The challenge to the trial court's order was rejected, and the proceedings were not interfered with.
Ratio Decidendi: Summoning of documents under Section 91 of the Code of Criminal Procedure, 1973 is warranted only on a clear showing of necessity or desirability for the relevant proceeding, and a vague or roving request aimed at fishing for material cannot be allowed.