R. Ganesh v. State of Tamil Nadu - S.294 CrPC - Document List
Code of Criminal Procedure 1973 - Section 294- In case any document has been filed by the prosecution or the accused in any Court, such document is required to be included in a list. The genuineness of the documents included in the list can be ascertained by the Court by calling upon the prosecution or the accused, as the case may be. If such document is not disputed, it can be read in inquiry, trial or other proceedings under Cr.P.C. without proving the signature of the person to whom it purports to be. As per proviso thereto, if necessary, it is on the discretion of the Court to require such signature to be proved, while applying the provision of Section 294 (3) Cr.P.C.r.P.C. Section 294 deals with documentary evidence while Section 296 deals with the formal character of some evidence which is on affidavit. (Para 4-6)
Case Info
Case Information
Case name: R. Ganesh v. The State of Tamil Nadu
Case no.: Criminal Appeal No. __ of 2026 arising out of SLP (Crl.) No. 1383 of 2026; impugned High Court order in Crl.R.C. (MD) No. 1481 of 2025).
Coram:Hon’ble Mr. Justice J.K. MaheshwariHon’ble Mr. Justice Atul S. Chandurkar
Judgment date: 27 April 2026 (order signed at New Delhi on April 27, 2026)
Caselaws and Citations Referred
- State of Punjab v. Naib Din, (2001) 8 SCC 578
The Supreme Court holds that Naib Din (which interprets Section 296 CrPC on evidence of formal character by affidavit) is not applicable to the present controversy under Section 294 CrPC.
Statutes / Laws Referred
- Code of Criminal Procedure, 1973
- Section 294 – No formal proof of certain documents (reproduced and applied in detail)
- Section 296 – Evidence of formal character on affidavit (referred to and distinguished)
Brief Summary (Three Sentences)
The appeal arose from the Madras High Court (Madurai Bench) order dismissing the accused’s petition under Section 294 CrPC seeking to mark certain documents, which he claimed were part of the prosecution’s chargesheet and document list. The Supreme Court held that Section 294 CrPC governs the admission or denial of genuineness of documents already on record and that the High Court had wrongly relied on State of Punjab v. Naib Din, which dealt instead with Section 296 CrPC and formal evidence by affidavit. Setting aside the High Court’s order, the Court remitted the Section 294 application to be reconsidered afresh (with liberty to the CBI to raise objections) and directed that the pending criminal appeal be decided expeditiously after such decision.