Accordingly, Justice Neena Bansal Krishna dismissed the CBI's petition under Section 482 CrPC and upheld the order of the Special Judge setting aside the Section 91 notice. It does not contemplate compelling an accused to create evidence or compile information by applying his mind and memory. On examining the CBI notice, the Court found that it did not seek the production of any specific pre-existing document. The Court further held that Section 91 CrPC cannot be used as a substitute for interrogation under Section 161 CrPC or to bypass the accused's right to silence. Placing reliance on the Shyamlal Mohanlal Choksi case, the Court affirmed that Section 91 CrPC does not apply to an accused person regarding the production of incriminating documents.