The Supreme Court held that a Trial Court cannot remain a passive spectator when crucial witnesses are necessary for deciding a criminal case fairly. In Anil Singh @ Anil Kumar Singh v. State of Bihar & Ors., the prosecution had failed to examine important witnesses, including an injured witness, the treating doctor and the Investigating Officer. The Court relied on Section 311 CrPC, which empowers courts to summon, examine or recall any person whose evidence appears essential for a just decision. The Court clarified that exercising this power does not necessarily amount to filling a lacuna in the prosecution case. Instead, it may be necessary to ensure that relevant evidence is placed before the court and that the accused receives a fair opportunity to respond. The Court directed the Trial Court to examine the material witnesses and thereafter conduct the Section 313 CrPC proceedings afresh. The judgment highlights the importance of judicial intervention, fair trial, material witnesses and the duty of courts to discover the truth.