Section 94 BNSS document requests require a demonstrated connection to the case and relevance to the charges.

The appellant, an accused in a Special Case involving alleged offences under Sections 420, 120-B and 34 of the IPC and Sections 4, 5 and 6 of the Chhattisgarh Depositors Interest Act, 2005, sought documents said to relate to an alleged investment of ₹40 lakh.

He claimed the original documents were held by Sahara Command Office, Lucknow, and applied under Section 94 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), for their production.

The Special Judge rejected the application, reasoning that the appellant could obtain the documents himself.

The appellant challenged that order; the trial was at the prosecution-evidence stage, with six witnesses examined.

Whether the Special Judge’s rejection of the appellant’s application under Section 94 BNSS for production of documents warranted interference

Whether the documents sought were sufficiently connected to the relevant society and relevant to the charges to justify their production

The application was made under Section 94 BNSS, the provision invoked by the appellant to seek production of documents.

The Court’s reasoning required the requested documents to have an identifiable connection to the relevant society and to be relevant to the alleged charges; the judgment cites no precedent or further statutory test.

The Court found that the application did not establish that the documents sought were connected with the society identified in the case, nor did the appellant produce material showing that Sahara Command Office, Lucknow, was that society’s head office.

The application also failed to demonstrate how the documents related to the alleged charges and was therefore vague and irrelevant.

On that basis, the Court declined to interfere with the Special Judge’s order.