Trial Court Must Adjudicate Pending Applications for Exhibiting Documents Before Proceeding with Cross-Examination

The petitioner, married to respondent No. 3 in February 2022, filed a complaint alleging cruelty and dowry demands under Section 498A IPC and the Dowry Prohibition Act

While trial was pending before the Additional Sessions Judge (FTC), Dantewada, the petitioner appeared for evidence on 11.02.2026 with original documents

The Trial Court allegedly refused to let her exhibit these documents despite photocopies being on record

On 12.03.2026, the petitioner moved an application seeking permission to exhibit said documents, which remained pending while the court proceeded to fix the matter for cross-examination

The petitioner approached the High Court seeking a writ of mandamus to compel the Trial Court to allow the application

1. Whether the Trial Court’s failure to adjudicate upon the petitioner’s application to exhibit documents before proceeding with cross-examination constitutes a violation of the right to a fair trial.

2. Whether a writ of mandamus should be issued directing the Trial Court to decide the pending interlocutory application.

The Court considered the procedural framework under Article 226 of the Constitution of India regarding the issuance of directions for the sub-ordinate judiciary

It emphasized the principles of the Code of Criminal Procedure (CrPC) and the Indian Evidence Act, which govern the production, proof, and admissibility of documents during a criminal trial

The doctrine of "fair trial" was central, ensuring that a complainant has a reasonable opportunity to prove relevant documents to avoid a miscarriage of justice

The High Court noted that the petitioner's grievance was narrowly focused on the "inaction" of the Trial Court regarding the application dated 12.03.2026

While the State argued that production does not automatically equate to admission and the respondent alleged delays caused by the petitioner's counsel, the Court found that the pending status of the application necessitated judicial intervention

The Court reasoned that keeping such an application pending while proceeding with cross-examination could prejudice the petitioner’s case.

The Court avoided ruling on the merits or admissibility of the documents themselves, maintaining that such determinations fall strictly within the Trial Court's jurisdiction under the Evidence Act

The Court held that while it would not express an opinion on the admissibility of the documents, the Trial Court must ensure an expeditious trial and avoid unnecessary adjournments to prevent further delays