Facts: The case involves an alleged assault occurring on 01.05.2020. The First Information Report (FIR) lodged on 03.05.2020 named seven accused persons but did not include the three petitioners in Writ Petition No. 1935/2024. These petitioners were family members of the main accused. It was only on 22.06.2020, nearly two months later, that the complainant filed a grievance with the Superintendent of Police regarding their non-inclusion, and subsequently named them as assailants in a statement recorded under Section 164 of the Cr.P.C. on 26.06.2020. The prosecution did not charge-sheet these individuals. However, during the trial, based on the examination-in-chief of the complainant (PW-1), the Trial Court exercised its power under Section 319 of the Cr.P.C. to add the three petitioners as accused, while refusing to add two other persons alleged to be conspirators.Procedural Posture: Two criminal writ petitions were filed before the Bombay High Court: one by the newly added accused challenging their inclusion, and another by the complainant challenging the Trial Court's refusal to add the two alleged conspirators.Issue: Whether the Trial Court was justified in summoning the petitioners as additional accused under Section 319 of the Cr.P.C. based on an examination-in-chief that contained significant improvements and contradicted earlier statements of injured eye-witnesses.Holding: No. The High Court quashed the order adding the three petitioners as accused and upheld the refusal to add the two alleged conspirators.Reasoning: The Court reasoned that the power under Section 319 of the Cr.P.C. is an extraordinary and discretionary power to be exercised sparingly. Referring to the Constitution Bench judgment in "Hardeep Singh vs. State of Punjab", the Court emphasized that the degree of satisfaction required is much higher than a mere prima facie case; it must appear that the evidence, if left unrebutted, would lead to conviction. In this instance, the petitioners were not named in the FIR or in any initial statements of injured eye-witnesses. The complainant's later deposition was deemed an "improvement" that did not inspire confidence. The Court held that the Trial Court failed to record the requisite "strong and cogent evidence" necessary to summon additional persons, especially when their inclusion appeared to be an afterthought to wreak vengeance against the main accused's family.