Saturday, 20 May 2023

Should the court provide copies of questions to be put to accused U/S 313 of CRPC to the public prosecutor and defence counsel and seek their assistance?

22. Before we part with this judgment, we must take a note of sub-section (5) added to Section 313 of CrPC w.e.f. 31st December 2009. Sub-section (5) reads thus:

313. Power to examine the accused.-

(1) … … …

(2) … … … …

(3) … … … …

(4) … … … …

(5) The Court may take help of Prosecutor and Defence Counsel in preparing relevant questions which are to be put to the accused and the Court may permit filing of written statement by the accused as sufficient compliance of this section.”

23. In many criminal trials, a large number of witnesses are examined, and evidence is voluminous. It is true that the Judicial Officers have to understand the importance of Section 313. But now the Court is empowered to take the help of the prosecutor and the defence counsel in preparing relevant questions. Therefore, when the Trial Judge prepares questions to be put to the accused under Section 313, before putting the questions to the accused, the Judge can always provide copies of the said questions to the learned Public Prosecutor as well as the learned defence Counsel and seek their assistance for ensuring that every relevant material circumstance appearing against the accused is put to him. When the Judge seeks the assistance of the prosecutor and the defence lawyer, the lawyers must act as the officers of the Court and not as mouthpieces of their respective clients. While recording the statement under Section 313 of CrPC in cases involving a large number of prosecution witnesses, the Judicial Officers will be well advised to take benefit of subsection (5) of Section 313 of CrPC, which will ensure that the chances of committing errors and omissions are minimized.

 REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. 1471 of 2023

Raj Kumar @ Suman    Vs State (NCT of Delhi).

(Before Abhay S. Oka and Rajesh Bindal, JJ.)

Author: Abhay S. Oka, J.

Dated: May 11, 2023.

Citation: 2023 SCC OnLine SC 609.

1. Leave granted.

FACTUAL ASPECTS

2. Appellant (accused no.2) was convicted by

the Sessions Court by the Judgment dated 27th

August 2003 for the offences punishable under

Section 302 read with Section 120B

of the Indian


Penal Code (for short, ‘IPC’). For the offence under

Section 302, the appellant was sentenced to

undergo life imprisonment. He was also convicted

for the offence punishable under Section 307 read

with Section 120B

of IPC, for which he was

sentenced to undergo rigorous imprisonment for 7

years.

3. The allegation against this accused, along

with one Vimal (since deceased) and five others,

was that on 01st October 1995, around 03:30 pm,

they conspired to criminally intimidate and commit

the murder of Jawahar Lal (PW3)

and his relatives.

The allegation is that PW3

was running his own

cable TV network, and the accused wanted him to

stop the said cable TV network. The allegation of

the prosecution is that on 01st October 1995 at

about 03:30 pm, the accused entered the house of

PW3

Jawahar Lal where he, along with his family

members, were residing. Accused nos.4 and 5 fired

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bullets from their revolvers at Omi Devi, mother of

PW3

and Chander Shekhar (deceased – brother of

PW3).

Accused no.3 and deceased Vimal attacked

Chander Shekhar (deceased) and Omi with daggers

and knives. PW3

and PW7

suffered serious

injuries. As noted earlier, Chander Shekhar died.

We may note that admittedly the only allegation

against the present appellant (accused no.2) is that

while 6 other accused entered the house of PW3,

the appellant was standing near the gate of the

gallery with katta (countrymade

handgun) in his

hand. By the impugned judgment, the High Court

has confirmed the conviction of the appellant.

SUBMISSIONS

4. The learned counsel appearing for the

appellant pointed out that only PW5

Ved Prakash

deposed that the appellant was standing near the

gate of the gallery with katta in his hand. However,

PW3,

in the crossexamination,

accepted that he

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had not seen the present appellant on the day of

the incident and his name was told to him by PW5.

Learned counsel submitted that though the High

Court, in paragraph 84 of the impugned judgment,

has recorded a finding that even PW13

had seen

the appellant, in fact, PW13

has not deposed

anything about the appellant.

5. He submitted that the only circumstance

appearing in the evidence against the appellant that

he was standing outside near the gate of the gallery

with a katta was not put to him in his statement

under Section 313 of the Code of Criminal

Procedure, 1973 (for short, ‘CrPC’). He submitted

that this argument was specifically canvassed

before the High Court, which finds a place in the

written submissions filed on behalf of the

appellants, but the High Court did not consider it.

He relied upon decisions of this Court in the case of

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Ranvir Yadav v. State of Bihar1; Sukhjit Singh

v. State of Punjab2; Maheshwar Tigga v. State

of Jharkhand3; and Samsul Haque v. State of

Assam4. He submitted that as a result of the

failure of the Trial Court to put the only

circumstance appearing against the appellant

during his examination under Section 313 of CrPC,

grave prejudice has been caused to the appellant

resulting in failure of justice.

6. Learned counsel representing the

respondentState

submitted that the appellant did

not crossexamine

PW5.

He relied upon a decision

of this Court in the case of Satyavir Singh Rathi,

Assistant Commissioner of Police & Ors. v.

State through Central Bureau of Investigation5.

He submitted that in this decision, this Court held

1 (2009) 6 SCC 595

2 (2014) 10 SCC 270

3 (2020) 10 SCC 108

4 (2019) 18 SCC 161

5 (2011) 6 SCC 1.

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that the objection regarding the omission or defect

in recording the statement under Section 313, CrPC

must be raised at the earliest so that the defect can

be cured. He submitted that the said contention

was raised 16 years after the passing of the

judgment by the Trial Court. He would, therefore,

submit that, at this stage, this objection cannot be

sustained. He submitted that the very fact that the

said objection was not raised at any time earlier

shows that there is no prejudice caused to the

appellant due to the failure of the Court to put the

only circumstance against the appellant to him

while recording his statement under Section 313,

CrPC.

OUR VIEW

7. We have considered the submissions. There

is no dispute that the only allegation against the

appellant was that while six accused entered the

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house of PW3,

the appellant was standing outside

with a katta in his hand. In paragraph 84 of the

impugned judgment, the High Court has observed

that the evidence of PW3,

as regards the appellant,

creates some doubt. However, it was held that the

evidence of PW5

and PW13

is clear and consistent

as regards his involvement. We have, therefore,

perused the evidence of the said three prosecution

witnesses. PW3

Jawahar Lal deposed about the

entry of 6 other accused into his house at about

03:30 pm on 01st October 1995. He did not depose

that the appellant was standing outside with a

katta in his hand. In further examinationinchief,

he stated that in his statement recorded by the

police, he has wrongly mentioned that the accusedRajinder

Kumar was guarding the spot. He stated

that it was the appellant who was guarding the

spot. The High Court has expressed doubt about

the version of PW3

concerning the involvement of

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the present appellant. The reason given by the

High Court is that PW3

also stated that on the day

of the incident, he did not see the appellant, but his

name was told to him by PW5

Ved Prakash.

Therefore, the testimony of PW3

cannot be relied

upon to implicate the appellant.

8. We have carefully perused the evidence of

PW13.

Though the High Court has observed that

PW13

has ascribed a role to the appellant of

standing outside with a katta in his hand, we find

that PW13

has made no such statement in his

evidence.

9. Thus, what remains is the evidence of PW5.

All that he stated in his examinationinchief

was

that he saw Raj Kumar standing at the gate of the

gallery with a katta in his hand. He identified the

appellant in the Court.

10. Hence, the only circumstance brought on

record against the present appellant is in the

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evidence of PW5,

who stated that the appellant

was standing outside near the gate of the gallery

with a katta in his hand. No overt act was

attributed to him. There is a long statement of the

appellant under Section 313 of CrPC in which as

many as 42 questions were put to the appellant.

Question no.13 is about what PW5

deposed.

Admittedly, it was not put to the appellant that it is

brought on record that he was standing outside

near the gate of the gallery with a katta in his hand.

It is true that the answer given by him to every

question is “I don’t know”. If all the circumstances

put to the appellant in his statement under Section

313 CrPC are carefully perused, any person of

ordinary intelligence will get the impression that

none of the prosecution witnesses has stated

anything against him. That is why one cannot find

fault with the appellant when he gave standard

answers to every question as nothing adverse

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against him was put to him. We may note here that

in paragraph 13 of the written submissions by the

appellant before the High Court, a specific

contention was raised that the only circumstance

appearing against the appellant was not put to him

in the statement under Section 313 of CrPC. It is

not in dispute that this part of the argument is not

considered by the High Court. We may also note

that the Trial Court has not reproduced the

submissions made by the learned counsel

appearing for the accused.

11. Thus, we will have to proceed on the footing

that the only alleged incriminating circumstance

appearing against the appellant in the evidence

produced by the prosecution has not been put to

him in his statement under Section 313 of CrPC

and, therefore, he had no opportunity to explain the

said circumstance. Moreover, his conviction is

based only on this circumstance.

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12. Therefore, we will have to consider the effect

of the aforesaid omission on the part of the Trial

Court. The law on this aspect is no longer res

integra. Apart from the decisions relied upon by

the learned counsel representing the parties, there

are other important decisions on this aspect. The

first relevant judgment is of a Bench of four Hon’ble

Judges of this Court in the case of Tara Singh v.

State6. The Court considered the provision of

Section 342 of the Code of Criminal Procedure,

1898 (for short, ‘CrPC of 1898’). Section 313 of

CrPC and Section 342 of CrPC of 1898 are in pari

materia. In paragraph 18, this Court held thus :

“18. It is important therefore that an

accused should be properly examined

under Section 342 and, as their

Lordships of the Privy Council indicated

in Dwarkanath

Varma v. Emperor [Dwarkanath

Varma v. Emperor, AIR 1933 PC 124 at

p. 130 : 1933 SCC OnLine PC 11] , if a

point in the evidence is considered

6 1951 SCC OnLine SC 49

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important against the accused and

the conviction is intended to be

based upon it, then it is right and

proper that the accused should be

questioned about the matter and be

given an opportunity of explaining it

if he so desires. This is an important

and salutary provision and I cannot

permit it to be slurred over. I regret to

find that in many cases scant attention

is paid to it, particularly in the Sessions

Courts. But whether the matter arises

in the Sessions Court or in that of the

Committing Magistrate, it is important

that the provisions of Section 342

should be fairly and faithfully observed.”

(emphasis added)

Again in paragraph 23, this Court held thus:

“23. Section 342 requires the accused

to be examined for the purpose of

enabling him “to explain any

circumstances appearing in the evidence

against him”. Now it is evident that

when the Sessions Court is required to

make the examination under this

section, the evidence referred to is the

evidence in the Sessions Court and the

circumstances which appear against the

accused in that court. It is not therefore

enough to read over the questions and

answers put in the Committing

Magistrate's Court and ask the accused

whether he has anything to say about

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them. In the present case, there was not

even that. The appellant was not asked

to explain the circumstances appearing

in the evidence against him but was

asked whether the statements made

before the Committing Magistrate and

his answers given there were correctly

recorded. That does not comply with the

requirements of the section.”

The second important decision on this aspect is the

decision of a Bench of three Hon’ble Judges of this

Court. This is a decision in the case of Shivaji

Sahabrao Bobade & Anr. v. State of

Maharashtra7. In paragraph 16 of the decision,

this Court examined the issue of noncompliance

with the requirements of Section 342 of CrPC of

1898. Paragraph 16 reads thus:

“16. The discovery of incriminating

materials pursuant to confessions made

by the accused constitutes the third

category of evidence. Obviously, the

confessions are inadmissible but the

discoveries are, provided they are

pertinent to the guilt of the accused. So

far as Accused 2 is concerned, his

statement resulted in the discovery of a

knife (Vide Panchnama, Ext. 13). Of

7 (1973) 2 SCC 793

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course, knives were discovered long ago

and not now but this knife lay buried

and was recovered by the accused from

a pit in the corner of a wall of his house.

There was human blood on the blade of

the knife, MO 5/1 according to the

chemical analyst's report. The second

accused's clothes also were picked up

by him pursuant to his statement. He

had worn a shirt and pants on the day

of occurrence and PW 13, a neighbour

deposes that the second accused had

come to him at about 6 p.m. on the

Monday when Hariba died and had

mentioned to him that since his own

house was locked he might be permitted

to keep his clothes in the witnesses

house. Thereafter he left his clothes

under an empty khokha from where he

himself took them out when he later

came in the company of the police.

There are bloodstains

on the clothes

and it is found by the chemical

examiner that the blood on the pants

are of the same blood group as that of

the deceased. When the second accused

was asked under Section 342, CrPC

about the report of the chemical

examiner noticing blood stains on the

shirt, MO 5/2 and of human blood on

the blade of the knife, MO 5/1, he

merely answered, “I do not know”. He

also described as false the fact of his

recovering the clothes and the knife.

Bald denial notwithstanding, we are

inclined to believe, with the learned

Judges of the High Court, that the knife

and the shirt have been identified as his

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and since he had recovered them,

thereby making the police discover the

fact, there was incriminating inference

available against the said accused. We

may notice here a serious omission

committed by the trial Judge and not

noticed by either court. The pants

allegedly worn at the time of the attack

by the second accused has stains of

blood relatable to the group of the

deceased. This circumstance binds him

to the crime a little clear but it is

unfortunate that no specific question

about this circumstance has been put to

him by the Court. It is trite law,

nevertheless fundamental, that the

prisoner's attention should be drawn

to every inculpatory material so as to

enable him to explain it. This is the

basic fairness of a criminal trial and

failures in this area may gravely

imperil the validity of the trial itself,

if consequential miscarriage of justice

has flowed. However, where such an

omission has occurred it does not

ipso facto vitiate the proceedings and

prejudice occasioned by such defect

must be established by the accused.

In the event of evidentiary material

not being put to the accused, the

court must ordinarily eschew such

material from consideration. It is also

open to the appellate court to call

upon the counsel for the accused to

show what explanation the accused

has as regards the circumstances

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established against him but not put

to him and if the accused is unable to

offer the appellate court any plausible

or reasonable explanation of such

circumstances, the Court may

assume that no acceptable answer

exists and that even if the accused

had been questioned at the proper

time in the trial court he would not

have been able to furnish any good

ground to get out of the

circumstances on which the trial

court had relied for its conviction. In

such a case, the Court proceeds on the

footing that though a grave irregularity

has occurred as regards compliance

with Section 342, CrPC, the omission

has not been shown to have caused

prejudice to the accused. In the present

case, however, the High Court, though

not the trial court has relied upon the

presence of blood on the pants of the

blood group of the deceased. We have

not been shown what explanation the

accused could have offered to this

chemical finding particularly when we

remember that his answer to the

question regarding the human blood on

the blade of the knife was “I do not

know”. Counsel for the appellants could

not make out any intelligent explanation

and the “blood” testimony takes the

crime closer to the accused. However,

we are not inclined to rely over much on

this evidentiary circumstance, although

we should emphasise how this

inadvertance of the trial court had led to

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a relevant fact being argued as

unavailable to the prosecution. Great

care is expected of Sessions Judges who

try grave cases to collect every

incriminating circumstance and put it to

the accused even though at the end of a

long trial the Judge may be a little

fagged out.”

(emphasis added)

13. Then we come to the decision of this Court in

the case of S. Harnam Singh v. State (Delhi

Admn.)8. In paragraph 22, this Court held thus :

“22. Section 342 of the Code of Criminal

Procedure, 1898, casts a duty on the

court to put, at any enquiry or trial,

questions to the accused for the purpose

of enabling him to explain any

circumstances appearing in the evidence

against him. It follows as a necessary

corollary therefrom that each

material circumstance appearing in

evidence against the accused is

required to be put to him specifically,

distinctly and separately. Failure to

do so amounts to a serious

irregularity vitiating the trial if it is

shown to have prejudiced the

accused. If the irregularity does not,

in fact, occasion a failure of justice, it

is curable under Section 537, of the

Code.”

8 (1976) 2 SCC 819

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(emphasis added)

14. Then we come to a decision in the case of

Samsul Haque4 relied upon by the learned counsel

for the appellant. In paragraphs 21 to 23, this

Court held thus :

“21. The most vital aspect, in our view,

and what drives the nail in the coffin in

the case of the prosecution is the

manner in which the court put the case

to Accused 9, and the statement

recorded under Section 313 CrPC. To

say the least it is perfunctory.

22. It is trite to say that, in view of

the judgments referred to by the

learned Senior Counsel, aforesaid, the

incriminating material is to be put to

the accused so that the accused gets

a fair chance to defend himself. This

is in recognition of the principles of

audi alteram partem. Apart from the

judgments referred to aforesaid by the

learned Senior Counsel, we may usefully

refer to the judgment of this Court

in Asraf Ali v. State of Assam [Asraf

Ali v. State of Assam, (2008) 16 SCC 328

: (2010) 4 SCC (Cri) 278] . The relevant

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observations are in the following

paragraphs : (SCC p. 334, paras 2122)

“21. Section 313 of the Code casts a

duty on the court to put in an

enquiry or trial questions to the

accused for the purpose of enabling

him to explain any of the

circumstances appearing in the

evidence against him. It follows as

necessary corollary therefrom that

each material circumstance

appearing in the evidence against

the accused is required to be put to

him specifically, distinctly and

separately and failure to do so

amounts to a serious irregularity

vitiating trial, if it is shown that the

accused was prejudiced.

22. The object of Section 313 of

the Code is to establish a direct

dialogue between the Court and

the accused. If a point in the

evidence is important against the

accused, and the conviction is

intended to be based upon it, it is

right and proper that the accused

should be questioned about the

matter and be given an

opportunity of explaining it.

Where no specific question has been

put by the trial court on an

inculpatory material in the

prosecution evidence, it would

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vitiate the trial. Of course, all these

are subject to rider whether they

have caused miscarriage of justice

or prejudice. This Court also

expressed a similar view in S.

Harnam Singh v. State (Delhi

Admn.) [S. Harnam Singh v. State

(Delhi Admn.), (1976) 2 SCC 819 :

1976 SCC (Cri) 324] while dealing

with Section 342 of the Criminal

Procedure Code, 1898

(corresponding to Section 313 of the

Code). Nonindication

of inculpatory

material in its relevant facets by the

trial court to the accused adds to

the vulnerability of the prosecution

case. Recording of a statement of

the accused under Section 313 is

not a purposeless exercise.”

23. While making the aforesaid

observations, this Court also referred to

its earlier judgment of the threeJudge

Bench in Shivaji Sahabrao

Bobade v. State of Maharashtra [Shivaji

Sahabrao Bobade v. State of

Maharashtra, (1973) 2 SCC 793 : 1973

SCC (Cri) 1033] , which considered the

fallout of the omission to put to the

accused a question on a vital

circumstance appearing against him in

the prosecution evidence, and the

requirement that the accused's attention

should be drawn to every inculpatory

material so as to enable him to explain

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it. Ordinarily, in such a situation, such

material as not put to the accused must

be eschewed. No doubt, it is recognised,

that where there is a perfunctory

examination under Section 313 CrPC,

the matter is capable of being remitted

to the trial court, with the direction to

retry from the stage at which the

prosecution was closed [Shivaji

Sahabrao Bobade v. State of

Maharashtra, (1973) 2 SCC 793 : 1973

SCC (Cri) 1033].”

(emphasis added)

15. Learned counsel for the respondent also

relied upon a decision of this Court in the case of

Vahitha v. State of Tamil Nadu9. This case does

not deal with the consequences of the omission

made while questioning the accused under Section

313 of CrPC. This deals only with a contingency

where evidence of the prosecution witnesses goes

unchallenged. Now we come to the decision of this

Court in the case of Satyavir Singh5 relied upon

by the learned counsel for the respondent. The

9 2023 SCC OnLine SC 174.

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decision holds that the challenge to the conviction

based on noncompliance

with Section 313 of CrPC

for the first time in the appeal cannot be

entertained unless the accused demonstrates that

prejudice has been caused to him. If an objection

is raised at the earliest, the defect can be cured by

recording an additional statement of the concerned

accused. The sum and substance of the said

decision is that such a long delay can be a factor in

deciding whether the trial is vitiated. Moreover,

what is binding is the decision of the larger Bench

in the case of Shivaji Sahabrao Bobade7, which

lays down that if there is prejudice caused to the

accused resulting in failure of justice, the trial will

vitiate.

16. The law consistently laid down by this Court

can be summarized as under:

(i) It is the duty of the Trial Court to put

each material circumstance appearing

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in the evidence against the accused

specifically, distinctively and separately.

The material circumstance means the

circumstance or the material on the

basis of which the prosecution is

seeking his conviction;

(ii) The object of examination of the

accused under Section 313 is to enable

the accused to explain any

circumstance appearing against him in

the evidence;

(iii) The Court must ordinarily eschew

material circumstances not put to the

accused from consideration while

dealing with the case of the particular

accused;

(iv) The failure to put material

circumstances to the accused amounts

to a serious irregularity. It will vitiate

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the trial if it is shown to have prejudiced

the accused;

(v) If any irregularity in putting the

material circumstance to the accused

does not result in failure of justice, it

becomes a curable defect. However,

while deciding whether the defect can be

cured, one of the considerations will be

the passage of time from the date of the

incident;

(vi) In case such irregularity is curable,

even the appellate court can question

the accused on the material

circumstance which is not put to him;

and

(vii) In a given case, the case can be

remanded to the Trial Court from the

stage of recording the supplementary

statement of the concerned accused

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under Section 313 of CrPC.

(viii) While deciding the question whether

prejudice has been caused to the

accused because of the omission, the

delay in raising the contention is only

one of the several factors to be

considered.

17. Now, we will have to apply the principles

enunciated by this Court to the facts of this case.

The High Court has reproduced the charge framed

on 04th July 1998 against the accused, which reads

thus :

“Charge

6. The charge framed against all the

accused by the order dated 4th July

1998 by the trial Court was as under :

(i) That on or before 1st October 1995

at around 3.30 pm at Delhi A1

to

A6

along with Vimal (since dead)

agreed to criminally intimidate and

commit the murder of Jawahar Lal

(PW3)

and his relatives on account

of the failure of PW3

to stop his

TV cable network in the area of

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Paschimpuri thereby committing

the offence of criminal conspiracy

punishable under Section 120B

IPC.

(ii) That at House No.618/3,

Paschimpuri on 1st October 1995,

in pursuance of the

aforementioned conspiracy, A4

and A5

fired bullets from their

respective revolvers on Smt. Omi

Devi and Chander Shekhar

whereas Vimal and A3

attacked

Chander Shekhar and Omi with

their respective dagger and knife

and committed their murders and

thus all of them had committed an

offence punishable under Section

302 read with 120B IPC.

(iii) All of them pursuant to the

criminal conspiracy attempted

to commit the murder of PW3

by firing bullets from their

revolvers on both PW3

and PW7

due to which both of them received

dangerous injuries and thereby all

of them committed an offence

punishable under Section 307 read

with 120B IPC.’

(emphasis added)

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18. In paragraph 7 of the High Court Judgment,

it is noted that a separate charge under Section 452

read with 120B

of IPC was framed against all

accused except the present appellant. Thus, the

charge as framed against the appellant was of being

a party to criminal conspiracy. There is also a

charge that all the accused fired bullets from their

revolver. Only based on the version of PW5

regarding the appellant’s presence with a weapon

outside the premises where the offence took place,

the involvement of the appellant has been held as

proved. There is absolutely no other evidence

against him. This is not a case where there are

several incriminating circumstances appearing

against the appellant in the evidence adduced by

the prosecution. This is a case where there is only

a solitary circumstance appearing in the evidence

against the appellant. The prosecution examined

Crl.A.@SLP(Crl.)No.11256 of 2018

Page 27 of 33

37 witnesses. The material against the appellant is

in the form of one sentence in the evidence of PW5.

As mentioned earlier, if we read 42 questions put to

the appellant in his statement under Section 313 of

CrPC, any accused having ordinary intelligence will

carry an impression that there is absolutely no

material against him. The appellant was not

confronted during his examination under section

313 of CrPC with the only allegation of the

prosecution against him. This is how, on facts, we

find that a serious prejudice was caused to the

appellant.

19. The incident is of 1995. It is not clear

whether this aspect was argued before the Trial

Court as the Trial Court has not reproduced the

submissions of the counsel for the appellant.

However, before the High Court, it was certainly

canvassed as it forms a part of the written

submissions.

Crl.A.@SLP(Crl.)No.11256 of 2018

Page 28 of 33

20. Even assuming that the defect or irregularity

was curable, the question is whether today, the

appellantaccused

can be called upon to explain the

said circumstance. More than 27 years have

passed since the date of the incident. Considering

the passage of time, we are of the view that it will

be unjust now at this stage to remit the case to the

Trial Court for recording further statement of the

appellant under Section 313 of CrPC. In the facts

of the case, the appellant cannot be called upon to

answer something which has transpired 27 years

back. There is one more aspect of the matter which

persuaded us not to pass an order of remand. The

said factor is that the appellant has already

undergone incarceration for a period of 10 years

and 4 months.

21. Before we part with this judgment, we must

take a note of subsection (5) added to Section 313 of CrPC w.e.f. 31st December 2009. Subsection (5)  reads thus :

“313. Power to examine the accused.(

1) … … …

(2) … … … …

(3) … … … …

(4) … … … …

(5) The Court may take help of

Prosecutor and Defence Counsel in

preparing relevant questions which are

to be put to the accused and the Court

may permit filing of written statement

by the accused as sufficient compliance

of this section.”

In many criminal trials, a large number of

witnesses are examined, and evidence is

voluminous. It is true that the Judicial Officers

have to understand the importance of Section 313.

But now the Court is empowered to take the help of

the prosecutor and the defence counsel in

preparing relevant questions. Therefore, when the

Trial Judge prepares questions to be put to the

accused under Section 313, before putting the

questions to the accused, the Judge can always

provide copies of the said questions to the learned

Public Prosecutor as well as the learned defence

Counsel and seek their assistance for ensuring that

every relevant material circumstance appearing

against the accused is put to him. When the Judge

seeks the assistance of the prosecutor and the

defence lawyer, the lawyers must act as the officers

of the Court and not as mouthpieces of their

respective clients. While recording the statement

under Section 313 of CrPC in cases involving a

large number of prosecution witnesses, the Judicial

Officers will be well advised to take benefit of subsection

(5) of Section 313 of CrPC, which will

ensure that the chances of committing errors and

omissions are minimized.

22. In 1951, while delivering the verdict in the

case of Tara Singh6, this Court lamented that in

many cases, scant attention is paid to the salutary

provision of Section 342 of CrPC of 1898. We are

sorry to note that the situation continues to be the

same after 72 years as we see such defaults in large

number of cases. The National and the State

Judicial Academies must take a note of this

situation. The Registry shall forward a copy of this

decision to the National and all the State Judicial

Academies.

23. In the circumstances, we are of the view that

the conviction of the appellant stands vitiated. In

the facts of the case, the option of remand will be

unjust. Accordingly, we allow the appeal and set

aside the conviction and sentence of the appellant

under the Judgment and Order dated 27th August

2003 passed by the learned Additional Sessions

Judge, Delhi, in Sessions Case No.9 of 2000.

Consequently, the impugned judgment of the High

Court is also set aside. We make it clear that both

judgments are set aside only insofar as the

appellant is concerned. We, accordingly, direct that

the respondent shall forthwith set the appellant at

liberty unless he is required to be detained in

connection with any other case.

……………………………J.

[ABHAY S. OKA]

……………………………J.

[RAJESH BINDAL]

New Delhi

May 11, 2023.


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