Can Section 91 CrPC be invoked to compel an accused to produce incriminating material? Calcutta High Court examines
The Court observed that issuance of summons to produce a document against a person asking him to produce a document does not ipso facto makes the said person as a witness however, it would be highly unjust if the word ‘person’ used in Section 91 of the Code of Criminal Procedure is presumed to include an accused.