As per case facts, an officer of the Cotton Corporation of India and his son allegedly conspired to buy cotton at a low market rate and then resell it to ... CCI at the higher Minimum Support Price using "benami" farmers who had insufficient land, causing a substantial loss to the government. The Special Court and High Court discharged the accused, relying heavily on an informal letter from CCI stating no loss was caused, which directly contradicted the CBI's chargesheet. The CBI appealed to the Supreme Court. The question arose whether the court, while considering discharge under Section 239 of the CrPC, can look at and rely upon extraneous material filed by the defense. Finally, the Supreme Court held that the lower courts committed a fundamental legal error by relying on a document filed by the defense at the discharge stage. The judicial mandate for Section 239 confines the examination only to the chargesheet and documents submitted by the prosecution under Section 173 to determine if the charge is "groundless," preventing a premature "mini-trial" of the defense. The orders of discharge were set aside, and the matter was sent back to the Special Court to decide on framing charges based solely on the prosecution's records