Shantanu Prakash vs Cbi & Ors

The petitioner Shantanu Prakash challenged an order refusing his application under Section 91 CrPC seeking production of documents during a CBI investigation involving Educomp Infrastructure and School Management Limited and Axis Bank. The petitioner argued he could not meaningfully answer investigation queries without access to the voluminous and old documents with which he was being confronted. The court dismissed the petition, holding that the Special Judge exercised discretion judiciously and the power under Section 91 is discretionary, but directed that the Investigating Officer must give the petitioner sufficient time to go through documents before answering questions.