Nitya Dharmananda @ K. Lenin vs Sri Gopal Sheelum Reddy Also Known As ...

The Supreme Court addressed the invocation of Section 91 of the Cr.P.C. at the charge framing stage, clarifying that while the accused cannot ordinarily invoke this section, the court may summon material not included in the chargesheet if it is crucial for justice. The Court emphasized that the necessity of such material must be assessed in relation to the charge framing stage, as established in State of Orissa v. Debendra Nath Padhi (2005) 1 SCC 568. The High Court's decision to allow the summoning of additional material was upheld, reinforcing the principle that justice must prevail even if the accused lacks a right to invoke Section 91 at this stage.