Selan Bank Plc v. Samanellya Teas (Private) Limited And 3 Others – sllr 2009 volume 1 page 134

In the case between SELAN BANK PLC and SAMANELIYA TEAS (PRIVATE) LIMITED and others, the issue concerned whether a court may compel a bank to produce a “Statement of Accounts” under Section 90(e) of the Evidence Ordinance, specifically addressing whether such a document qualifies as primary or secondary evidence. It was determined that a derivative document compiled from original records does not fall within the statutory scope, reaffirming that Section 90(e) authorizes only inspection of original entries and not the creation of derivative statements. The court relied on the construction of Section 90(e) in conjunction with Sections 65 and 66 of the Evidence Ordinance, emphasizing that statutory powers must be confined to expressly permitted evidentiary documents. The decision clarified th