Specificity is required for seeking unrelied criminal case documents; a vague omnibus request will not justify interference.

Access to unrelied material in criminal proceedings may be sought to secure a fair trial under Article 21, but the accused must identify the documents with reasonable specificity. Sections 173 and 207 of the Code require supply of the police report, relied-upon statements and documents forwarded with it, while only limited inspection-related safeguards apply to voluminous records. Here, the request was found vague because no particulars of the allegedly unrelied documents were furnished and the prosecution stated that relied-upon material had already been supplied. The refusal of relief was therefore upheld.

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Issues: Whether a petition seeking supply of all unrelied documents under the criminal procedure regime, without specifying the documents with particulars, deserved interference in quashing proceedings.

Analysis: The application was examined in the light of the scheme under Sections 173 and 207 of the Code of Criminal Procedure, 1973, which require furnishing of the police report, relied-upon statements, and documents forwarded with the report, while also recognising limited court power regarding exclusion of parts of statements and inspection of voluminous documents. The decision in V.K. Sasikala and the later guidelines on criminal trials were noticed for the principle that an accused may seek access to material forwarded to court but not relied upon by the prosecution, in aid of a fair trial under Article 21 of the Constitution of India. At the same time, the Court noted that the accused must identify the documents sought with reasonable specificity. In the present case, the request was found to be vague, as no particulars of the allegedly unrelied documents were furnished, and the prosecution had asserted that the relied-upon documents had already been supplied. On that basis, the refusal to grant the relief was treated as justified.

Conclusion: The vague request for blanket supply of unspecified documents did not warrant interference, and the rejection of the application was upheld.

Final Conclusion: The challenge failed because the accused did not make a specific, identifiable claim to documents allegedly withheld from disclosure, and no illegality or perversity was found in the impugned order.

Ratio Decidendi: A claim for access to unrelied material in a criminal trial can succeed only when the accused makes a specific and reasonable request identifying the documents sought; a vague and omnibus demand does not justify judicial interference.

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