The High Court answered significant questions related to Section 91 of CrPC which deals with Summons to produce documents or other things. Essentially, the Bench of Justice Sheel Nagu and Justice Sunita Yadav examined as to when can an accused as also a victim, invoke this Section during a criminal proceeding and held as below:

1. An accused cannot invoke Section 91 Cr.P.C. during pendency of investigation.

2. However, an accused can invoke Section 91 on and after the filing of charge-sheet.

3. Section 91 can also be invoked by the other stakeholders i.e. victim and also prosecution.

4. Court can also invoke Section 91 Cr.P.C. suo moto.

5. All the above invocation by any stakeholder is subject to satisfaction of the Court about desirability and necessity of the document sought to be produced.