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Issues: (i) Whether an order directing production of income tax returns during cross-examination was an interlocutory order barred from revision or an intermediate order amenable to revision under the Code of Criminal Procedure, 1973; (ii) Whether the High Court should interfere under Section 482 of the Code of Criminal Procedure, 1973 with the revisional order restricting further cross-examination to relevant questions.
Issue (i): Whether an order directing production of income tax returns during cross-examination was an interlocutory order barred from revision or an intermediate order amenable to revision under the Code of Criminal Procedure, 1973.
Analysis: An interlocutory order is one of a purely interim or temporary nature which does not decide the rights or liabilities of the parties. By contrast, an intermediate order lies between institution and final disposal and determines an intervening matter relating to the cause. The direction to produce income tax returns for the purposes of cross-examination was treated as an order made under Section 91 of the Code of Criminal Procedure, 1973 and, in that context, as having sufficient finality for revision. The restriction on treating it as a mere interlocutory order was therefore rejected.
Conclusion: The order was held to be a revisionable intermediate order and not an interlocutory order barred by Section 397(2) of the Code of Criminal Procedure, 1973.
Issue (ii): Whether the High Court should interfere under Section 482 of the Code of Criminal Procedure, 1973 with the revisional order restricting further cross-examination to relevant questions.
Analysis: Cross-examination must remain confined to the defence taken and to matters relevant for determining the offence. A party cannot use cross-examination to frustrate the objective of a summary trial or to harass the witness on irrelevant matters. The revisional order, which limited further cross-examination to repayment-related questions, was found consistent with that principle. No compelling circumstance was shown to justify exercise of inherent powers to override the order.
Conclusion: No interference under Section 482 of the Code of Criminal Procedure, 1973 was warranted.
Final Conclusion: The challenge to the revisional order failed, and the High Court declined to disturb the restriction placed on further cross-examination.
Ratio Decidendi: An order directing production of documents for a specific purpose in criminal proceedings may constitute a revisionable intermediate order, and the High Court will not use inherent powers to enlarge cross-examination beyond relevant issues absent compelling circumstances.
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