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20. It is submitted that the investigating agency cannot obtain fresh documents during the trial without obtaining permission under Section 173(8) of the CrPC. It is also submitted that in the present case, the AIR 1989 SC 1785 prosecution sought to introduce additional documents that were not part of the original chargesheet and had not been placed on record during the course of prosecution evidence. It is further submitted that since the prosecution failed to seek the requisite permission under Section 173(8) of the CrPC, the introduction of these documents is not permissible under the law.

22. It is submitted that the prosecution was fully aware that the screenshots relied upon did not support its case since the time of recording of statements of relevant witnesses. It is also submitted that despite this knowledge, the prosecution did not take any steps to introduce additional documents during its evidence stage or at the time of filing the chargesheet. It is further submitted that the prosecution also failed to offer any justification for the delay in filing its application and the learned Trial Court erred in presuming the reasons for this delay without any pleadings or explanations being provided by the prosecution.

43. Upon perusal of the aforesaid extracts of the impugned order, it is made out that the learned Trial Court explicitly observed that the document was already a part of the record, and its omission was a procedural oversight rather than a suppression of evidence. The learned Court below observed that the prosecution is not attempting to introduce a new piece of evidence or alter the nature of the case, rather ensuring that the full details of an already submitted document are placed for proper adjudication. Moreover, the document does not introduce any new facts or allegations against the accused but merely completes the evidentiary chain that was already relied upon by the prosecution. The learned Trial Court, in allowing the application, emphasized the need for completeness in the evidentiary record, holding that an omission of this nature should not result in an incomplete appreciation of facts by the Court.

68. However, this Court finds that no prejudice has been caused to the accused/petitioner in the present case. The submission of the complete document does not introduce any new facts or allegation but only provides a complete version of a document that was already in the case record. Furthermore, the accused will be given the opportunity to cross- examine the re-called witnesses regarding the additional details in the document and thus, the ability to test the evidence through cross- examination defeats any claim of procedural unfairness.