Section 91 CrPC limits document production to relevant materials; unrelated company records and URLs were rightly declined.

Section 91 CrPC permits production only of documents necessary or desirable for trial and believed to be in a person's possession or power; it cannot support a roving or fishing inquiry. In a cheque dishonour complaint, documents concerning company affairs, third-party entities, redundant URLs and other materials not shown to be relevant to adjudication were properly declined. By contrast, the income tax returns and the complainant's bank statements were sufficiently connected to the complaint and available for production, so the limited direction for their production was justified. No legal infirmity was found in refusing the remaining documents.

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Issues: Whether the order allowing production of only the income tax returns and bank statements under Section 91 of the Code of Criminal Procedure, 1973, while declining the remaining documents, suffered from any legal infirmity.

Analysis: Section 91 can be invoked only for documents that are necessary or desirable for the purpose of trial and can be directed to be produced only from a person in whose possession or power they are believed to be. The request must show relevance to the adjudication of the complaint, and the provision cannot be used for a roving or fishing inquiry. Applying these principles, the documents relating to company affairs, third-party entities, redundant URLs, and other materials not shown to be material for the cheque dishonour complaint were correctly declined. By contrast, the income tax returns and the complainant's bank statements were found to be relevant to the complaint and available for production, and their direction for production was justified.

Conclusion: The limited allowance of production of the income tax returns and bank statements was in law, and the refusal of the remaining documents did not warrant interference.

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