Use of complaint and supporting papers by complainant-witness permitted, while investigation papers cannot replace personal testimony.

A complainant who also acts as investigating officer cannot use investigation papers as a substitute for his own evidence, but he may refer to the complaint after cognizance when examined as PW-1. Limited reliance on supplied papers is permissible for recalling factual particulars such as TIN numbers, since a witness is not expected to memorise every detail. On that basis, the trial magistrate properly overruled the objection to such reference, and no interference was warranted.

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Issues: Whether the trial court was justified in permitting the complainant, who was also the investigating officer, to refer to the complaint contents and supporting papers while being examined as PW-1.

Analysis: The complainant, as investigating officer, was not entitled to rely on investigation papers as a substitute for his own evidence, but the complaint, after cognizance, could be looked into by him when examined as PW-1. The Court also noted that a witness cannot be expected to memorize factual particulars such as TIN numbers, and limited reference to the papers furnished to the accused was permissible for that purpose.

Conclusion: The trial magistrate correctly overruled the objection, and no interference was warranted.

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