The petitioner, Lokesh Raipure, was arraigned as an accused in a criminal case (Crime No.620/2021) alleging forgery of a 'Will' under Sections 419, 420, 465, 467, 468, and 471 of the IPC, following a family dispute over inheritance after his father's death. The Economic Offence Wing, Nagpur issued a notice dated 28.2.2022 under Section 91 of the CrPC directing the petitioner, as an accused, to produce the original 'Will' for investigation. The petitioner challenged this notice before the Bombay High Court (Nagpur Bench), contending that compelling an accused to produce documents violates Article 20(3) of the Constitution of India (protection against self-incrimination). The court relied on the Supreme Court's five-judge bench decision in State of Gujarat vs. Shyamlal Mohanlal Choksi (AIR 1965 SC 1251) and the eleven-judge bench decision in State of Bombay vs. Kathi Kalu Oghad (AIR 1962 SC 180), which held that Section 94 of the old CrPC (corresponding to Section 91 of the CrPC, 1973) does not apply to accused persons. Accordingly, the High Court found the notice issued to the petitioner to be illegal and liable to be quashed.