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9.1 The document, which was sought to be read as substantive evidence under Section 294 Cr.P.C. in the referred case, is an injury report filed by the prosecution, which is considered as document, as defined in Section 29 of the IPC. It was observed in the judgment of Saddiq And Ors. Vs. State (supra) that, before the Code of Criminal Procedure, 1973 came into force an injury report could not be read in evidence as it was only a writing of the doctor made at the time of the examination of the injuries of the injured person. The injury report R/SCR.A/3973/2018 CAV JUDGMENT DATED: 06/01/2022 contains observation of the Doctor regarding the nature, dimension and location of the injuries and also his opinion regarding their duration and the instrument with which they were caused. The doctor who prepared the injury report was required to enter the witness box during the inquiry or trial to prove the injuries of the injured person. He could refresh his memory under Section 159 of the Evidence Act by referring to the injury report prepared by him. The injury report is proved under Section 67 of the Evidence Act corroborated by deposition in Court under Section 157 of the Evidence Act. Under sub-section (3) of Section 294 of the Cr.P.C., an injury report filed by the prosecution under sub-section (1) of Section 294 of Cr.P.C. may be read as substantive evidence in place of the deposition of the doctor who prepared it, if its genuineness is not disputed by the accused. If the genuineness of the injury report is disputed, then the doctor who examined the injured person must appear in the witness box to prove his injury report and in such a case the statement of the doctor would be the substantive evidence and the injury report may be used to corroborate or discredit his testimony.
9.2 There can be no dispute to the object of enacting Section 294 Cr.P.C. The object in enacting Section 294 Cr.P.C. is to shorten the proceedings. It provides the mode and manner in which document relied upon by the prosecution or defence could be proved without any formal proof thereof. When the genuineness R/SCR.A/3973/2018 CAV JUDGMENT DATED: 06/01/2022 of the document filed by one party is not disputed and thereby admitted by the other party, the document can be read as substantive evidence by the Court; however it is to be kept in mind that the proviso to section gives discretion to the Court to call for the proof of signature on the documents. Section 294 Cr.P.C. lays down that when any document is filed before any Court by the prosecution or the accused, the particulars of every such document shall be included in a list and the prosecution or the accused, as the case may be, or the pleader for the prosecution or the accused, if any, shall be called upon to admit or deny the genuineness of each such document; and as provided under sub-section (3) of section 294 Cr.P.C., and when the genuineness of any document is not disputed, such document may be read in evidence in any inquiry, trial or other proceeding under the Code without proof of the signature of the person purported to be signed. But it requires mention that the said section is not absolute since proviso to sub-section (3) gives discretion to the Court and thus is not mechanical for the Judge to blindly accept such document to be read in evidence during the trial, inspite of the fact that genuineness is not disputed.
9.4 It is significant to note that section 294 Cr.P.C. does not refer to a document, which, even if exhibited, cannot be read as a piece of evidence. The injury report by itself does not prove anything, as it is not a substantive piece of evidence. It is an evidence of the doctor on oath in regard to the injuries which alone is substantive evidence. The injury report can only be used to corroborate or contradict the doctor and it cannot be a substitute for the evidence of the doctor. If the injury report filed by the prosecution has been accepted as genuine by the accused it is admissible to be read as evidence. The prosecution, while presenting the police report under section 173 can support the same with documents and they are required to be considered at the time of framing of charge. Thus, in a case where genuineness of injury report or the postmortem report is not disputed by the accused and the reports are read as 'substantive evidence', it may still be necessary to R/SCR.A/3973/2018 CAV JUDGMENT DATED: 06/01/2022 examine the Doctor concerned to clarify his opinion mentioned in the report or to obtain his opinion on questions of medical nature, which may be involved in the case, then it may become necessary for the Court to examine such relevant person under Section 311 of Cr.P.C. Even if, the genuineness of the documents filed by the prosecution or the accused under sub-section (1) Cr.P.C. is not disputed by the opposite party, the Court may require the proof of the signature of the person by whom it is proposed to be signed under the proviso of Section (3) of section 294 Cr.P.C. For such a case, the signatory of the document must appear in the Court and prove his signature and the document, thereafter to be read as substantive document.

17. In Shamsher Singh Verma Vs. State of Haryana (supra), the Hon'ble Apex Court, held as under:

"14. In view of the definition of 'document' in Evidence Act, and the law laid down by R/SCR.A/3973/2018 CAV JUDGMENT DATED: 06/01/2022 this Court, as discussed above, we hold that the compact disc is also a document. It is not necessary for the court to obtain admission or denial on a document under sub-section (1) to Section 294 CrPC personally from the accused or complainant or the witness. The endorsement of admission or denial made by the counsel for defence, on the document filed by the prosecution or on the application/report with which same is filed, is sufficient compliance of Section 294. Similarly on a document filed by the defence, endorsement of admission or denial by the public prosecutor is sufficient and defence will have to prove the document if not admitted by the prosecution. In case it is admitted, it need not be formally proved, and can be read in evidence. In a complaint case such an endorsement can be made by the counsel for the complainant in respect of document filed by the defence.