Forensic examination of disputed handwriting may be ordered when signatures are denied on a material document in a cheque case.

In proceedings under Section 138 of the Negotiable Instruments Act, 1881, where the complainant specifically denied the handwriting and signatures on a disputed receipt relied on by the accused, the court held that forensic examination was relevant to a just adjudication. The trial court's refusal of the request on conjectural grounds was unsustainable because the document had evidentiary significance and could be tested through expert comparison. The request for FSL examination was allowed, the rejection order was set aside, and the trial proceedings were stayed until receipt of the FSL report.

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Issues: Whether the disputed receipt, whose handwriting and signatures were denied by the complainant, ought to have been ed to the Forensic Science Laboratory for comparison, and whether the order rejecting the request was sustainable.

Analysis: The petition arose from proceedings under Section 138 of the Negotiable Instruments Act, 1881, where the accused relied on a receipt marked as Exhibit D01A. The complainant denied both the signatures and handwriting on that document. In such a situation, expert examination of the disputed document was relevant for a just adjudication of the matter, and the trial court's rejection of the request on conjectural grounds failed to account for its evidentiary value.

Conclusion: The request for FSL examination was allowed, and the order rejecting it was set aside.

Final Conclusion: The disputed document is to be examined by the handwriting expert, and the trial proceedings remain stayed until the FSL report is received.

Ratio Decidendi: Where the signatures and handwriting on a material document are specifically denied, the court may direct forensic comparison if the document can bear on the just adjudication of the case.

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