Section 294 CrPC mandates calling for admission or denial of documents regardless of their perceived relevancy.

The petitioners (accused) are facing trial under Section 138 of the Negotiable Instruments Act in S.C.C. No. 5745 of 2019

The accused filed an application (Exh. 36) under Section 294 of the Code of Criminal Procedure (Cr.P.C.) seeking to produce certain documents—including a Sale Deed, Correction Deed, and TILR maps—and requesting the court to direct the complainant to admit or deny their genuineness

While the Trial Court allowed the production of these documents via applications at Exh. 34 and 35, it rejected the request under Section 294 Cr.P.C. on November 14, 2025

The Trial Court reasoned that the documents were irrelevant because the cheques in question were issued pursuant to a compromise settlement reached in 2017, subsequent to the dates of the proposed documents

The petitioners moved the High Court to quash this rejection.

1. Whether the procedure under Section 294 of the Cr.P.C., which requires the opposite party to admit or deny the genuineness of documents, is mandatory or discretionary

2. Whether a Trial Court can refuse to invoke Section 294 Cr.P.C. based on a preliminary assessment of the documents' relevancy when production has already been permitted

The court primarily interpreted Section 294 of the Cr.P.C., which stipulates that when a document is filed, the prosecution or the accused "shall" be called upon to admit or deny its genuineness

The court relied on the Full Bench judgment in Shaikh Farid Hussainsab v. State of Maharashtra, which established that Section 294 was introduced to dispense with avoidable waste of time and facilitate speedy trials by removing the need for formal proof of undisputed documents

The court also considered Section 136 of the Indian Evidence Act regarding the court's role in determining relevancy, but distinguished it from the procedural mandate of Section 294 Cr.P.C.

The High Court determined that the Trial Court committed a procedural error by rejecting the application on the grounds of "relevancy" at the stage of admission/denial

The court reasoned that the word "shall" in Section 294 Cr.P.C. indicates a mandatory intent, leaving no discretion to the court to deny the request once the documents are on record

It was observed that calling upon the complainant to admit or deny documents does not amount to a judicial determination of their admissibility or evidentiary value; rather, it is a procedural step to identify which documents require formal proof

Since the Trial Court had already permitted the production of the documents under Exh. 34, it was bound to follow the Section 294 procedure

The court further noted that determining relevancy at this stage was premature, as the accused has the right to lead evidence to substantiate their defense

It held that Section 294 Cr.P.C. is a mandatory provision intended to expedite trials and the Trial Court cannot bypass it based on a prima facie view of relevancy

The Trial Court was directed to call upon the complainant to admit or deny the documents in accordance with the law and was further directed to dispose of the 2019 complaint within six months