Relevant documents may be taken on record in cheque dishonour complaints when they aid a just decision and cause no prejudice.

Relevant documents may be taken on record in a complaint under Sections 138 and 141 of the Negotiable Instruments Act before notice under Section 251 CrPC where they assist a just decision on the accused's role in the company and do not prejudice the defence or alter the nature of the proceedings. The additional material was found relevant to whether the petitioner was responsible for the company's day-to-day affairs, and its reception was not treated as filling a lacuna. The procedural order was upheld, and the challenge failed.

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Issues: Whether the order allowing the complainant to place additional documents on record in a complaint under Sections 138 and 141 of the Negotiable Instruments Act, 1881, before the stage of notice under Section 251 of the Code of Criminal Procedure, 1973, suffered from any legal infirmity.

Analysis: The additional documents were found to be relevant to the question whether the petitioner was responsible for the day-to-day affairs of the company. The Court treated the material as capable of assisting a just decision and held that no prejudice would be caused to the accused by taking the documents on record. Reliance was placed on the principle that procedural powers must be exercised to meet the ends of justice and that relevant evidence may be permitted where it does not amount to filling a lacuna or changing the nature of the case.

Conclusion: The impugned order was upheld and the petition was dismissed.

Final Conclusion: The complaint court was permitted to retain the additional documents on record, and the challenge to that procedural order failed.

Ratio Decidendi: Relevant documents may be taken on record at an appropriate stage when their reception aids a just decision and does not cause prejudice to the accused or alter the nature of the proceedings.

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