Short answer. Not automatically. Rule 132, Section 9 says that once a witness's examination by both sides is concluded, that witness cannot be recalled without leave of the court, and the court decides whether to grant that leave based purely on its own discretion and what the interests of justice call for — recall is a request, not a right.
What the law says
After the examination of a witness by both sides has been concluded, the witness cannot be recalled without leave of the court. The court will grant or withhold leave in its discretion, as the interests of justice may require.
Rule 132, Section 9 — Recalling witness. Read the full provision →
Why recall isn't automatic once examination ends
Section 9 draws a clear line: after the examination of a witness by both sides has been concluded, the witness cannot be recalled without leave of the court. Once both direct and cross-examination are done, the witness's role in giving testimony is treated as finished unless the court specifically allows otherwise — a party cannot simply bring the same witness back up for more questioning on their own initiative.
What 'leave of the court' means in practice
Getting leave means asking the court's permission before the recall can happen. This is not a formality the court is expected to grant as a matter of course — the rule frames it as something the party must specifically obtain, which usually means presenting the request to the judge and explaining why the witness needs to be questioned again, rather than assuming the recall will simply be allowed.
The standard the court applies
The rule gives the court real latitude here: it will grant or withhold leave in its discretion, as the interests of justice may require. That phrasing does not lock the judge into a fixed checklist — the decision turns on the court's own assessment of what fairness and the proper resolution of the case call for in that particular situation, which means the outcome can vary from case to case even on similar facts.
What this means if you think you need a recall
If something comes up after a witness has already been examined by both sides — a point you overlooked, or new information that makes their earlier testimony worth revisiting — the right move under this section is to ask the court for leave rather than treat the witness as automatically available again. Because the standard is discretionary, being clear and specific about why the recall serves the interests of justice gives the request its best chance of being granted — vague requests are far less likely to succeed than ones tied to a concrete reason.