P. Chhaganlal Daga vs M. Sanjay Shaw

The Supreme Court held that the High Court erred in interfering with the trial magistrate's order allowing the complainant to produce additional evidence under Section 311 of the Code of Criminal Procedure, 1973, in a case under Section 138 of the Negotiable Instruments Act, 1881. The Court emphasized that the power to receive additional evidence is broad and should be exercised to ensure a just decision, even after the closure of evidence. The Court reinstated the trial court's order, asserting that the additional material was necessary for a fair adjudication of the case.