Central Bureau Of Investigation vs R.S. Pai And Another

The Supreme Court held that under Section 173(5) of the Code of Criminal Procedure, 1973, the prosecution is permitted to produce additional documents gathered during the investigation even after the charge-sheet has been submitted, provided that the documents are relevant to the case. The Court found that the Special Court's rejection of the CBI's application for additional documents was erroneous, as the Investigating Officer's initial omission of relevant documents did not preclude their later introduction. Consequently, the appeal was allowed, and the order of the Special Court was set aside.