As per case facts, applicants Ganesh Prasad Garg and Bablu Mishra filed a revision against an order from the Additional Sessions Judge that arrayed them as accused persons. They were ... initially not charge-sheeted by the police, who found no involvement, and the trial court had already taken cognizance and framed charges against other accused. Subsequently, the complainant filed an application under Section 213 of B.N.S.S. (old Section 193 of Cr.P.C.) to summon the applicants as additional accused. The applicants argued that the trial court erred in invoking this section based on material in the charge sheet after cognizance and charge framing, stating that additional accused could only be summoned after evidence under Section 319 Cr.P.C. The question arose whether additional accused can be summoned under Section 213 BNSS (old Section 193 Cr.P.C.) after cognizance, charge framing, and when the trial is at the evidence stage, based on a complainant's application rather than on evidence recorded by the court itself. Finally, the Court ruled that the trial court's reasoning was flawed because if grounds existed, cognizance against the proposed accused should have been taken earlier. The power to summon additional accused under Section 319 Cr.P.C. (which applies at the evidence stage) is not dependent on their being named in the FIR or the police charge sheet, but solely on evidence adduced before the court during the trial. The impugned order was set aside, with a direction that the trial court may proceed under Section 319 Cr.P.C. only after recording and cross-examining the evidence of the complainant and other eye-witnesses.