Justice Sunil Beniwal, dealing with a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, further clarified that mere marking of a document as an exhibit does not amount to its proof or admission. The Court dismissed a petition challenging the trial court’s decision to mark the subsequently produced bank return memo as Exhibit-9 in a complaint under Section 138 of the Negotiable Instruments Act, 1881.
