Complainant-originated documents are admissible under Section 242(2) CrPC if produced through the prosecution during trial.

The complainant and others entered into agreements for residential units but alleged that the accused failed to deliver possession despite receiving payments, leading to charges of cheating and criminal conspiracy.

During the trial for a warrant case instituted on a police report, the complainant filed an application under Section 242(2) of the Code of Criminal Procedure (“CrPC”) to bring original documents (agreements, receipts, etc.) on record during prosecution evidence.

The Trial Court allowed the production, noting the documents were submitted "through the prosecution".

The Petitioner/accused challenged this, arguing that a complainant/witness cannot independently introduce documents not part of the original charge-sheet.

The Revisional Court affirmed the Trial Court's order, prompting this petition.

1. Whether a document originating from the complainant can be taken on record at the stage of prosecution evidence in a warrant case upon an application moved through the prosecution under Section 242(2) of the CrPC.

The court primarily applied Section 242 of the CrPC (corresponding to Section 265 of the BNSS, 2023), which mandates the Magistrate to take all evidence produced in support of the prosecution.

Manoj Patel v. State of Madhya Pradesh established that a witness may produce relevant documents in their possession during trial.

Dhariwal Industries Ltd. v. Kishore Wadhwani, affirming that while a complainant must act under the Prosecutor’s direction, the prosecution may adopt documents supplied by them.

Rajendra Prasad v. Narcotic Cell, holding that oversight in producing evidence does not constitute an "irreparable lacuna" and Courts should facilitate the discovery of truth.

The Court clarified that Section 242(2) CrPC empowers a Magistrate to summon documents upon a prosecution application, while Section 242(3) mandates the receipt of all evidence produced in support of the prosecution.

The Court distinguished between the origin of a document and its mode of production; it held that if the prosecution adopts a document and moves the application, the statutory requirement is satisfied regardless of whether the document originated from the investigating agency or the complainant.

In this case, the Trial Court explicitly recorded that the documents were routed "through the prosecution," a finding the Petitioner failed to challenge in revision.

Furthermore, since the documents were original versions of photocopies already in the charge-sheet, no "surprise" or prejudice was caused to the accused.

The Court emphasized that procedural technicalities must not obstruct the quest for truth.

The Court held that the source of the document is irrelevant as long as the mode of production follows the legal channel and the accused retains the right to cross-examine and challenge admissibility.

Finding no jurisdictional error or perversity in the lower courts' orders, the petition was dismissed.