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V. K. Mishra & Anr. vs. State of Uttarakhand & Anr. (SC)

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Code of Criminal Procedure, 1973–Sec. 161–Statements of witness recorded u/s. 161 are not a substantive piece of evidence but can be used for the following purposes.
(i) of contradicting such witness by an accused under Sec. 145 of Evidence Act, and
(ii) the contradiction of such witness also by the prosecution but with the leave of the Court, and
(iii) re-examination of the witness if necessary.