Section 91 CrPC permits additional documents at any stage when needed for just adjudication in income-tax complaints.

Section 91 CrPC was held to permit production of additional documents at the pre-charge evidence stage where the Court considers them necessary or desirable for a just adjudication. The additional official records, including a Section 148 notice, were allowed because they did not alter the substratum of the Section 276CC complaints and the accused retained full opportunity to challenge their evidentiary value. The challenge to the trial court's orders therefore failed, and no interference under Section 482 CrPC was warranted.

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Issues: Whether the complainant could be permitted, under Section 91 of the Code of Criminal Procedure, 1973, to place additional documents on record at the stage of evidence in complaints under Section 276CC of the Income-tax Act, 1961.

Analysis: The petitions challenged trial court orders allowing the Income-tax Department to place on record additional official documents, including a notice under Section 148 of the Income-tax Act, 1961, during pre-charge evidence. The Court held that the language of Section 91 of the Code of Criminal Procedure, 1973 confers wide power on the Court to summon or permit production of any document or thing if its production appears necessary or desirable for any inquiry, trial or other proceeding, and the provision is not confined to any particular stage. The Court further held that the object of the provision is to enable a just decision by bringing all material evidence before the Court. The additional documents were official departmental records, their production did not alter the substratum of the complaints, and the accused would have full opportunity to cross-examine and contest their evidentiary value.

Conclusion: The challenge to the trial court's orders failed. Permission to place the additional documents on record was upheld, and no interference was warranted under Section 482 of the Code of Criminal Procedure, 1973.

Ratio Decidendi: Section 91 of the Code of Criminal Procedure, 1973 may be invoked at any stage of the proceeding if the Court considers the document necessary or desirable for a just adjudication, and its use is not barred merely because the material was already in a party's possession.

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