The expenses to summon the witnesses fromyour side shall be borne by your client
The desired document may be asked to be produced before court by the plaintiff by filing a petition
Discovery of documents—A party may also move the Court for discovery of documents which are or have been in possession or power of any other party to the suit, and which relate to any matter in question in the suit. The other party shall made answer on affidavit in Form 5, Appendix C to the Code and must made a full and complete disclosure along the lines indicated in this Form (Order XI, Rules 12 and 13). The production of documents can be resisted on three grounds; viz. (i) that these are evidence exclusively of the party‘s own case or title, (ii) that these are privileged; and (iii) when the party called upon to produce being a public officer considers, that a disclosure would be injurious to public interest. The affidavit shall be treated as conclusive to the existence, possession and the grounds of objection to the production of the document, unless the Court is reasonably certain that the objection is misconceived and the document is of such a nature that the party cannot properly make the assertions contained in the affidavit. The Court can also examine the documents to decide the claim about privilege. The Court can order the production of the documents at any stage of the trial and a party can serve notice on the other party for the inspection of any of the documents mentioned in the pleadings or the affidavit of the other party (Order XI, Rules 14 and 15). The failure to comply with such order or notice does not justify the striking out of the defence, though the party at fault shall not afterwards be at liberty to put such document in evidence, except with the leave of the Court and on such terms as to costs as the Court thinks fit.