Tuesday, 7 March 2023

Whether the right of accused to have fair trial is violated if the court is examining witnesses through video linkage?

 Since the purpose of enactment of Electronic Video Linkage Rules for Courts (Kerala), 2021 itself is to examine the witnesses whose presence could not be secured without undue delay or expenses and for other reasons stated in Rule 8(23), a person who has been employed in Dubai whose presence could not be secured without delay and also without spending travelling and other expenses when allowed to be examined through video linkage, in terms of the rules, in such a case the petitioner has no right to say that cross examination by video linkage is not effective and as good as physical mode and, therefore, such examination should not be permitted. In fact, the examination of the witness either through physical mode or through video linkage, the same makes no difference as far as the right of the accused to cross examine the witness is concerned. However, the intention of the petitioner securing physical presence of the witness for examination may be one with ulterior motive, which I am not inclined to discuss in detail. That apart, it is worthwhile to note that the framers of the Rules even visualised the argument of this nature while implementing the Rules and they vigilantly implemented Rule 8(24) and the said provision provides that subject to the orders of the Court, if any party or his authorised person is desirous of being physically present at the Remote Point at the time of recording of the evidence, it shall be open for such party to make arrangements at his own cost. If so, the dread persuasion of the petitioner could be addressed by resorting to Rule 8(24), subject to the orders of the Court. {Para 10}

11. It is pertinent to note that, if the submissions of the learned counsel for the petitioner is accepted, the same is akin to make the Electronic Video Linkage Rules for Courts (Kerala), 2021 redundant. The principles governing interpretation do not permit interpretation of a provision of law or an enactment to make the same as redundant.

12. Epitomizing the discussion, it is held that the learned Special Judge rightly allowed the petition with a view to secure examination of CW1, whose presence could not be secured without undue delay or expenses, through video linkage and with bona fide intention to dispose of a case of the year 2012, pending for the last 11 years, without further delay. Therefore, the order impugned does not suffer from any infirmity or requires any interference and the order impugned is liable to be confirmed.

IN THE HIGH COURT OF KERALA AT ERNAKULAM

CRL.MC NO. 1465 OF 2023

GOPAL.C. Vs  CENTRAL BUREAU OF INVESTIGATION

PRESENT

 MR. JUSTICE A. BADHARUDEEN

Dated: 3rd day of March, 2023

This petition has been filed under Section 482 of the Code of

Criminal Procedure and the petitioner is the sole accused in

C.C.No.3/2012 pending before the Special Judge (SPE/CBI)-II,

Ernakulam. The petitioner impugns order in Crl.M.P.No.18/2023

in C.C.No.3/2012 sprang up from the common order in

Crl.M.P.Nos.18 and 19 of 2023 dated 13.01.2023.

2. Heard the learned counsel for the petitioner as well as

the learned Deputy Solicitor General of India (`DSGI' for short

hereinafter).

3. Summary of the factual events. Public Prosecutor (CBI)

had filed Crl.M.P.Nos.18 and 19 of 2023 before the Special Court

and sought examination of the defacto complainant in

C.C.No.3/2012 by name Sujesh.P.S, who is the first witness (CW1)

in the case, through video linkage on the ground that the first

witness has been working in Dubai and his presence for

examination could not be secured without delay or expenses.

Similarly, the Public Prosecutor (CBI) also filed

Crl.M.P.No.19/2023 to examine CW16 through video linkage.

4. The petitioner herein objected Crl.M.P.No.18/2023,

where examination of CW1 was sought for through video linkage,

while not raising any objection in Crl.M.P.No.19/2023, where

CW16 was sought to be examined through video linkage. The

objection raised by the petitioner herein before the Special Court

was that the accused would be denied and estopped from

effectively cross examining CW1, if he could not be examined by

securing his physical presence. Further the demeanour and

approach of the witness during cross examination were vital and

therefore, examination of CW1 in physical form is essential to

protect the interest of the accused and to properly defend the case.

5. The learned Special Judge appraised the contentions in

view of the objection raised by the petitioner herein regarding

examination of CW1 through video linkage. The learned Special

Judge found that in the advanced era of technology, a witness could

effectively be cross examined even through video linkage and in

order to ensure such facility, the Electronic Video Linkage Rules

for Courts (Kerala), 2021 was enacted. Accordingly, the objection

raised by the petitioner herein was negated and finally the Special

Court allowed examination of CW1 through video linkage facility.

6. The learned counsel for the petitioner herein, who

challenged the order passed by the learned Special Judge in

Crl.M.P.No.18/2023, reiterated the contentions raised before the

Special Court mainly on the submission that an effective cross

examination of CW1 would be possible only when physical

examination would be permitted and the right of the accused to

cross examine the witness effectively, would be curtailed by opting

the mode of video linkage and the same is detrimental to the

interest of the accused.

7. Whereas the learned DSGI zealously opposed this

contention and argued that if the apprehension of the petitioner

holding the view that effective cross examination will be possible

only through physical examination, is appreciated, the very

purpose of enactment of Electronic Video Linkage Rules for Courts

(Kerala), 2021 would become ineffective and, therefore, the prayer

could not be allowed. According to him, the learned Special Judge,

rightly negatived the contention in this regard. It is also pointed

out by the learned DSGI that cross examination of a witness either

through video linkage or through physical mode, would be equally

effective and there is no need to discriminate the proceedings in

any manner and to make the rules inoperative.

8. While appraising the rival contentions on the issue,

Rules 7 and 8 of the Electronic Video Linkage Rules for Courts

(Kerala), 2021 notified as on 28.05.2023, assumes significance.

Rule 7 provides the mode of service of summons in relation to

witnesses proposed to be examined or heard through electronic

video linkage and Rule 8 deals with examination of persons. As

per Rule 8(25) it has been provided that the examination through

Electronic Video Linkage shall be treated as substantive

compliance of the provisions of the Code of Criminal Procedure

1973 (Act 2 of 1974), Code of Civil Procedure, 1908 (Act 5 of

1908), Criminal Rules of Practice, Kerala, Civil Rules of Practice,

Kerala or any other law which requires personal appearance of

parties, witnesses or any other Required Person for the purpose of

any enquiry, trial or any other proceedings in or in relation to the

Subordinate Courts or Tribunals.

9. Similarly, Rule 8(23) provides that when a Required

Person is unable to reach the Court point or the Remote Point due

to sickness or physical infirmity or due to any genuine reason

which the court may decide, or the presence of the Required Person

cannot be secured without undue delay or expenses, the Court may

authorise the conduct of the proceedings through Electronic Video

Linkage from the place where the Required Person is situated. In

such circumstances, the Court may direct the use of portable Video

system. The authority for the same shall be given by the Court to

the concerned Co-ordinator or any other person deemed fit by the

Court. Thus going by Rule 8(23), it has been stipulated that for

any genuine reason which the court may decide or the presence of

the Required Person cannot be secured without undue delay or

expenses, the Court may authorise the conduct of the proceedings

through Electronic Video Linkage from the place where the

Required Person is situated. In the present case, which has been

pending for the last 11years, in order to facilitate trial of the matter

without being stalled further, the learned Public Prosecutor (CBI)

filed Crl.M.P.No.18/2023 highlighting the reasons precisely stated

in Rule 8(23) and, accordingly, the Special Court allowed the

petition, so as to avoid further delay in examining the crucial

witness.

10. Since the purpose of enactment of Electronic Video

Linkage Rules for Courts (Kerala), 2021 itself is to examine the

witnesses whose presence could not be secured without undue

delay or expenses and for other reasons stated in Rule 8(23), a

person who has been employed in Dubai whose presence could not

be secured without delay and also without spending travelling and

other expenses when allowed to be examined through video

linkage, in terms of the rules, in such a case the petitioner has no

right to say that cross examination by video linkage is not effective

and as good as physical mode and, therefore, such examination

should not be permitted. In fact, the examination of the witness

either through physical mode or through video linkage, the same

makes no difference as far as the right of the accused to cross

examine the witness is concerned. However, the intention of the

petitioner securing physical presence of the witness for

examination may be one with ulterior motive, which I am not

inclined to discuss in detail. That apart, it is worthwhile to note

that the framers of the Rules even visualised the argument of this

nature while implementing the Rules and they vigilantly

implemented Rule 8(24) and the said provision provides that

subject to the orders of the Court, if any party or his authorised

person is desirous of being physically present at the Remote Point

at the time of recording of the evidence, it shall be open for such

party to make arrangements at his own cost. If so, the dread

persuasion of the petitioner could be addressed by resorting to Rule

8(24), subject to the orders of the Court.

11. It is pertinent to note that, if the submissions of the

learned counsel for the petitioner is accepted, the same is akin to

make the Electronic Video Linkage Rules for Courts (Kerala), 2021

redundant. The principles governing interpretation do not permit

interpretation of a provision of law or an enactment to make the

same as redundant.

12. Epitomizing the discussion, it is held that the learned

Special Judge rightly allowed the petition with a view to secure

examination of CW1, whose presence could not be secured without

undue delay or expenses, through video linkage and with bona fide

intention to dispose of a case of the year 2012, pending for the last

11 years, without further delay. Therefore, the order impugned

does not suffer from any infirmity or requires any interference and

the order impugned is liable to be confirmed.

13. Accordingly the petition fails and is dismissed.

The interim order granted in this matter stands vacated and

the Special Jude can go on with examination of CW1 through

video linkage facility.



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