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S.N.BHARGAVA
Ratan Lal – Appellant
Versus
Kamla Devi – Respondent
The judgment indicates that the court found the order disallowing the cross-examination by pigeon-hole method to be illegal and irregular. The court emphasized that such a restriction on cross-examination impairs the fundamental right of a party to test the veracity and correctness of a witness's statement. It was held that denying the opportunity to show signatures on admitted documents as a means of cross-examination constitutes a failure to exercise the court's jurisdiction properly, leading to a miscarriage of justice. Consequently, the court set aside the order of the lower court and allowed the application for cross-examination by the pigeon-hole method, underscoring that procedural rules should serve justice and not hinder it.
2.The petitioners filed a suit for specific performance against the respond-ents, for an agreement executed by them on 6.12,1970. The plaintiffs closed their evidence and the defendants evidence was in progress. One of the defendant-respondents witness, Ghanshyam was being examined and cross-examination was in progress. He denied the signatures of Mohan Lal on the agreement (Ex. 9). Thereafter, the petitioners submitted an application in writing that they may be allowed to cross-examine the witness by way of pigeon hole i.e. by show-ing only the signatures of Mohan Lal on some other documents without telling the contents thereof. But the trial court did not allow such type of cross-exami-nation. The trial court, not only dismissed the application filed by the petitioners but closed further cross-examination by the petitioners. It is against this order that the present revision petition has been filed.
3. Learned counsel for the petitioners has drawn my att
None of the cases in the provided list explicitly indicate that they have been overruled, reversed, or treated as bad law. The case law excerpt provided discusses the Supreme Court's power to correct its errors in exercise of its inherent jurisdiction, particularly in cases affecting fundamental rights, but there is no indication within this text that this case has been overruled or discredited in subsequent rulings.
[Followed]
None identified. The case law statement appears to be a general legal principle rather than a precedent that has been explicitly followed in subsequent decisions.
[Distinguished, Criticized, Questioned, Reversed, Abrogated]
No explicit language or context in the provided excerpt indicates that this case has been distinguished, criticized, questioned, reversed, or abrogated in later rulings. Without additional case law references or judicial treatment, these categories cannot be confidently assigned.
The treatment of this case law is unclear because the provided excerpt does not include references to subsequent judicial treatment, citations, or case history. It is a standalone statement of legal principle without indication of its current standing or judicial treatment.
**Source :** A. R. Antulay VS R. S. Nayak - Supreme Court
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