Section 294 Cr.P.C. permits multiple petitions post-charges to admit documents without formal proof if undisputed, aiding speedy trial.

The petitioner assails the order dated 11.12.2025 in Crl.M.P.No.1465 of 2024 in Spl.C.C.No.06 of 2021 on the file of VIII Additional City Civil Court, Chennai (Special Court CBI), in dismissing the petition filed under Section 294 of Cr.P.C. as not pressed and granting liberty to file fresh petition.

2. The respondent/complainant had filed a complaint under Section 44(1) of the Prevention of Money Laundering Act, 2002 [hereinafter referred to as “the PML Act”] against the petitioners/accused 1 & 4 for an offence under Section 3 of the PML Act. The trial court took cognizance and the charges were framed against the accused on 12.04.2022.

3. The complainant had filed a petition under Section 294 of Cr.P.C. to receive the list of documents filed in Judicial Form No.78 as per the Criminal Rules of Practice, 2019. The relief sought for reads as follows;

“a. The property documents/conveyance deeds/titles deeds registered by the accused persons in the concerned Sub Registrar Offices, contained in Part-C (Book 1 to 7) of Annexure-B (Relied Upon Documents) and;

b. The statement of accounts of the accused persons maintained with the bank of the relevant bank witnesses contained in Part-E (Book 1 to 4) along with the Compact Disks, Certificates U/s.65-B of Indian Evidence Act and 2A of Banker’s Book of Evidence Act of Annexure-B (Relied Upon Documents).”

4. The petitioners/accused filed counter resisting the petition and the petition was also heard. The complainant had, however, filed a memo seeking to withdraw the petition with liberty to file a fresh petition after obtaining certified / authenticated copies. The trial Court, by order dated 11.12.2025, dismissed the petition as not pressed, granting liberty to file a fresh petition. Now the order is assailed mainly on the ground that the rights accrued to the petitioners had been taken away by allowing the petition to be withdrawn with liberty to file afresh. The petitioners are mainly aggrieved by the liberty granted to the respondent to file a fresh petition.

5. Heard the rival submissions and perused the materials available on record.

6. In a criminal trial, once the charges are framed, it is upon the prosecution to bring in the evidences to prove the charges beyond reasonable doubt. In cases involving large number of witnesses and voluminous documents, to facilitate speedy trial and to curtail unnecessary processes, Section 294 of Cr.P.C. allows both prosecution and defense to file documents, which provides for admission and denial of documents where no formal proof of certain documents is required.

7. For easy reference, Section 294 of Cr.P.C. is extracted hereunder;

“294. No formal proof of certain documents.- (1) Where 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.

(2) The list of documents shall be in such form as may be prescribed by the State Government.

(3) Where the genuineness of any document is not disputed, such document may be read in evidence in any inquiry, trial or other proceeding under this Code without proof of the signature of the person to whom it purports to be signed:

Provided that the Court may, in its discretion, require such signature to be proved.”

8. In normal circumstances, any document that is filed is to be proved by exa