In Shiv Baran Vs. State of U.P., the Supreme Court upheld a trial court’s directive issuing a summon to an additional accused under Section 319 CrPC, underlining the fact that plausible evidence at trial, e.g., consistent eye-witnesses can support adding an individual to the trial even if being left out in the chargesheet. The Court deprecated the interference by the High Court, making it clear that Section 319 gives courts jurisdiction to thwart guilty individuals from going scot-free because of investigative failures and needs to be applied with judicial prudence.