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5. The trial advanced to the complainant evidence (CE) stage. On 28.08.2024, fresh evidence was tendered, followed by an application on 11.09.2024 for additional documents, which was withdrawn. A renewed application dated 01.10.2024 under Section 311 CrPC read with Section 165 of the Indian Evidence Act sought to introduce WhatsApp conversations, transcripts of phone/video recordings, and Section 65B certificates, asserting these evidenced the petitioner's admissions of liability as alluded to in Para 18 of the original complaint. The impugned order allowed this application, scheduling CE and orders on the interim compensation application for 16.12.2024.

(emphasis supplied) Though not explicitly referencing Section 311 CrPC, the order aligns with the application's invocation thereof, reflecting the Magistrate's assessment that the documents--electronic records of purported admissions by the petitioner and his son Vikramjit Singh--are essential for substantiating the transaction and rebutting the defence of cheque misuse. The order was rendered post-hearing arguments, ensuring procedural fairness, and SAURABH Digitally signed by SAURABH PARTAP PARTAP SINGH LALER SINGH Date: 2025.08.12 LALER 17:38:16 +0530 Cr Appeal / 122/2025 Bhai Manjeet Singh Vs. Radhika Chowdhury (Deceased through LR Ms. Shreya Kapoor) advances the trial without concluding it, thereby preserving the adversarial process.

33. In Sethuraman (supra) Hon'ble Supreme Court of India held as under:-

"Secondly, what was not realised was that the orders passed by the trial court refusing to call the documents and rejecting the application under Section 311 CrPC, were interlocutory orders and as such, the revision against those orders was clearly barred under Section 397(2) CrPC. The trial court, in its common order, had clearly mentioned that the cheque was admittedly signed by the SAURABH Digitally signed by SAURABH PARTAP PARTAP SINGH LALER SINGH Date: 2025.08.12 LALER 17:40:01 +0530 Cr Appeal / 122/2025 Bhai Manjeet Singh Vs. Radhika Chowdhury (Deceased through LR Ms. Shreya Kapoor) respondent-accused and the only defence that was raised, was that his signed cheques were lost and that the appellant complainant had falsely used one such cheque. The trial court also recorded a finding that the documents were not necessary. This order did not, in any manner, decide anything finally. Therefore, both the orders i.e. one on the application under Section 91 CrPC for production of documents and other on the application under Section 311 CrPC for recalling the witness, were the orders of interlocutory nature, in which case, under Section 397(2), revision was clearly not maintainable. Under such circumstances, the learned judge could not have interfered in his revisional jurisdiction. The impugned judgment is clearly incorrect in law and would have to be set aside. It is accordingly set aside. The appeals are allowed."

34. This ratio was reiterated in Situ Ramanath Shastri v. IFCI Factors Ltd. (CRL.M.C. 586/2021, Delhi High Court, 30.08.2022), emphasizing non- interference in evidential management absent finality.

35. It is trite law that an order passed under Section 311 Cr.P.C. is purely an interlocutory order and a Criminal Revision against an interlocutory order is clearly barred under Section 438(2) BNSS [397(2) CrPC]. Therefore, the present revision petition filed against order dated 25.11.2024 passed by the Ld. Magistrate allowing additional evidence under Section 311 Cr.P.C, is thus, not maintainable.