Sunday, 20 January 2013

complaint or a chargesheet cannot straightaway be laid down before the special court under the Act.


Moly Vs State of Kerala, AIR 2004, SC 1890
The Court examined whether special court can straightaway take cognizance of offences 
under SC/ST Act without being committed to it by Magistrate?--Held, “no”.
The Court observed that the Section 194 of CrPC imposes an interdict on all Courts of 
Session against taking cognisance of any offence as a Court of original jurisdiction - Can 
take cognisance only if 'the case has been committed to it by a Magistrate - Exceptions 
are when Code itself has provided differently in express language regarding taking of 
cognisance or when any other law has provided differently in express language regarding 
taking cognizance of offences under such law - Special Court under this Act is essentially 
a Court of Session and it can take cognizance of offence when case is committed to it by 
Magistrate in accordance with provisions of Code - A complaint or a charge-sheet cannot 
straight away be laid down before Special Court under Act - Gangula Ashok and Anr v 
State of A P (2000 Indlaw SC 601) and Vidyadharan v State of Kerala (2003 Indlaw SC 
998) followed.
The Court said that Section 193 of the Code has to be understood in the aforesaid 
backdrop. Hence a special court under the SC/ST Act is essentially a court of session and 
it can take cognizance of the offence when the case is committed to it by the Magistrate 
in accordance with the provisions of the Code. In other words, a complaint or a chargesheet cannot straightaway be laid down before the special court under the Act.



DATE OF JUDGMENT: 23/03/2004






These appeals involve identical issues and are taken up 
for disposal together. 
Appellants faced trial for alleged commission of 
offences punishable under Sections 3(1)(iii), 3(1)(v) and 
3(1)(x) of the Scheduled Castes and Scheduled Tribes 
(Prevention of Atrocities) Act, 1989 (in short 'the Act').  
The Trial Court found the appellants guilty and imposed 
sentences.  Appeal before the High Court did not bring any 
relief to them.  
The primary stand taken in this appeal is that the 
Trial Court could not have suo moto entertained and 
registered the complaint as a sessions case.  
Learned counsel for the respondent-State supported the 
judgment of the courts below stating that this plea is 
taken for the first time in this Court and was not taken 
before the Courts below.     
Pristine question to be considered is whether the 
Special Judge could take cognizance of the offence straight 
away without the case being committed to him. If the Special 
court is a Court of Session, the interdict contained in 
Section 193 of the Code of Criminal Procedure, 1973 (for 
short the 'Code') would stand in the way. It reads thus:
"193. Cognizance of offences by Courts 
of Session- Except as otherwise expressly 
provided by this Code or by any other law for 
the time being in force, no Court of Session 
shall take cognizance of any offence as a 
court of original jurisdiction unless the 
case has been committed to it by a Magistrate 
under this Code." 

So the first aspect to be considered is whether the 
Special Court is a Court of Session. Chapter II of the Code 
deals with "Constitution of Criminal Courts and Offices". 
Section which falls thereunder says that :

"there shall be, in every State, the 
following classes of criminal courts, 
namely:

(i) Courts of Sessions;"

The other classes of criminal courts enumerated 
thereunder are not relevant in this case and need not be 
extracted. 

Section 14 of the Act Says that:

"for the purpose of providing for 
speedy trial, the State Government shall, 
with the concurrence of the Chief Justice of 
the High Court, by notification in the 
Official Gazette, specify for each district 
a Court of Session to be a Special Court to 
try the offences under this Act."


So it is for trial of the offences under the Act that a 
particular Court of Session in each district is sought to be 
specified as a Special Court. Though the word 'trial' is not 
defined either in the Code or in the Act it is clearly 
distinguishable from inquiry. The word 'inquiry' is defined 
in Section 2(g) of the Code as 'every inquiry, other than a 
trial, conducted under this Code by a Magistrate or court'.  
So the trial is distinct from inquiry and inquiry must 
always be a forerunner to the trial. The Act contemplates 
only the trial to be conducted by the Special Court. The 
added reason for specifying a Court of Session as a Special 
Court is to ensure speed for such trial. "Special Court" 
is defined in the Act as "a Court of Session specified as a 
Special Court in Section 14" (vide Section 2(1)(d).

Thus the Court of Session is specified to conduct a 
trial and no other court can conduct the trial of offences 
under the Act. Why did Parliament provide that only a Court 
of Session can be specified as a Special Court? Evidently 
the legislature wanted the Special Court to be a Court of 
Session. Hence the particular Court of Session, even after 
being specified as a Special Court, would continue to be 
essentially a Court of Session and designation of it as a 
Special Court would not denude it of its character or even 
powers as a Court of Session. The trial in such a Court can 
be conducted only in the manner provided in Chapter XVIII of 
the Code which contains a fascicules of provisions for 
'trial before a Court of Session". 

Section 193 of the Code has to be understood in the 
aforesaid backdrop. The Section imposes an interdict on all 
Courts of Session against taking cognizance of any offence 
as a Court of original jurisdiction. It can take cognizance 
only if 'the case has been committed to it by a Magistrate', 
as provided in the Code. Two segments have been indicated in 
Section 193 as exceptions to the aforesaid interdict. One 
is, when the Code itself has provided differently in express 
language regarding taking of cognizance, and the second is 
when any other law has provided differently in express 
language regarding taking cognizance of offences under such 
law. The word 'expressly' which is employed in Section 193 
denoting those exceptions is indicative of the legislative 
mandate that a Court of Session can depart from the 
interdict contained in the Section only if it is provided 
differently in clear and unambiguous terms. In other words, 
unless it is positively and specifically provided 
differently no Court of Session can take cognizance of any 
offence directly, without the case being committed to it by 
a Magistrate. 

Neither in the Code nor in the Act is there any 
provision whatsoever, not even by implication, that the 
specified Court of Session (Special Court) can take 
cognizance of the offence under the Act as a Court of 
original jurisdiction without the case being committed to it 
by a Magistrate. If that be so, there is no reason to think 
that the charge-sheet or a complaint can straight away be 
filed before such Special Court for offences under the Act. 
It can be discerned from the hierarchical settings of 
criminal courts that the Court of Session is given a 
superior and special status. Hence we think that the 
legislature would have thoughtfully relieved the Court of 
Session from the work of performing all the preliminary 
formalities which Magistrates have to do until the case is 
committed to the Court of Session. 

A reading of the concerned provisions makes it clear 
that subject to the provisions in other enactments all 
offences under other laws shall also be investigated, 
inquired into, tried and otherwise dealt with under the 
provisions of the Code. This means that if another enactment 
contains any provision which is contrary to the provisions 
of the Code, such other provision would apply in place of 
the particular provision of the Code. If there is no such 
contrary provision in other laws, then provisions of the 
Code would apply to the matters covered thereby.  This 
aspect has been emphasized by a Constitution Bench of this 
Court in para 16 of the decision in A.R. Antulay v. Ramdas 
Sriniwas Nayak (1984 (2) SCC 500).  It reads thus"

"Section 4(2) provides for offences 
under other law which may be investigated, 
inquired into, tried and otherwise dealt with 
according to the provisions of the Code of 
Criminal Procedure but subject to any 
enactment for the time being in force 
regulating the manner or place of 
investigation, inquiring into, trying or 
otherwise dealing with such offences. In the 
absence of a specific provision made in the 
statute indicating that offences will have to 
be investigated, inquired into, tried and 
otherwise dealt with according to that 
statute, the same will have to be 
investigated, inquired into, tried and 
otherwise dealt with according to the Code of 
Criminal Procedure. In other words, Code of 
Criminal Procedure is the parent statute 
which provides for investigation, inquiring 
into and trial of cases by criminal courts or 
various designations."

Section 5 of the Code cannot be brought in aid for 
supporting the view that the Court of Session specified 
under the Act obviate the interdict contained in Section 193 
of the Code so long as there is no provision in the Act 
empowering the Special Court to take cognizance of the 
offence as a Court of original jurisdiction. Section 5 of 
the Code reads thus:

"5.- Saving- Nothing contained in this 
Code shall, in the absence of a special 
provision to the contrary, affect any special 
or local law for the time being in force, or 
any special jurisdiction or power conferred, 
or any special form of procedure prescribed, 
by any other law for the time being in 
force."

This Court in Directorate of Enforcement v. Deepak 
Mahajan (1994 (3) SCC 440) on a reading of Section 5 in 
juxtaposition with Section 4(2) of the Code, held as 
follows:

"It only relates to the extent of 
application of the Code in the matter of 
territorial and other jurisdiction but does 
not nullify the effect of Section 4(2). In 
short, the provisions of this Code would be 
applicable to the extent in the absence of 
any contrary provision in the special Act or 
any special provision excluding the 
jurisdiction or applicability of the Code".


Hence, we have no doubt that a Special Court under this 
Act is essentially a Court of Session and it can take 
cognizance of the offence when the case is committed to it 
by the Magistrate in accordance with the provisions of the 
Code. In other words, a complaint or a charge-sheet cannot 
straight away be laid down before the Special Court under 
the Act. We are re-iterating the view taken by this Court 
in Gangula Ashok and Anr. v. State of A.P. (2000 (2) SCC 
504) and in Vidyadharan v. State of Kerala (2004 (1) SCC 
215) in above terms with which we are in respectful 
agreement. The Sessions Court in the case at hand, 
undisputedly has acted as one of original jurisdiction, and 
the requirements of Section 193 of the Code were not met.  

Though the plea relating to lack of jurisdiction was 
not raised before the lower Courts, in view of the 
undisputed position on facts and inasmuch as a pure question 
of law without any factual controversy is involved, we feel 
interference on the facts of the case is called for.    
          
One more plea which was pressed by learned counsel for 
the appellants is that continuance of the proceedings before 
the appropriate Court in the manner prescribed in law would 
serve no useful purpose in view of the long passage of time.  
We do not find any substance in this plea. It is for the 
Competent Court to decide regarding the action to be taken 
next, after hearing both sides as provided in Section 227 of 
the Code. No direction can be given to the said Court at 
this premature stage as to what course the Court should 
adopt in dealing with the complaint. It is open to the 
appellants to raise all their contentions at that stage if 
they want to make a plea for discharge. We make it clear 
that as and when such plea is made to the Judge of the 
Competent Court, he shall pass appropriate orders in 
accordance with law.

With the aforesaid directions and observations the 
appeals are finally disposed of.


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