Supreme court guidelines for Preparation of Tabulated Charts in all the judgments of Criminal cases

82. Preparation of Tabulated Charts in all the

judgments:

82.1 All trial Courts dealing with criminal matters

shall, at the conclusion of the judgment, incorporate

tabulated charts summarizing: -

a. Witnesses examined,

b. Documents exhibited, and

c. Material objects (muddamal) produced and

exhibited.

82.2. These charts shall form an appendix or

concluding segment of the judgment and shall be

prepared in a clear, structured and easily

comprehensible format.

83. Standardized Chart of Witnesses

83.1. Each criminal judgment shall contain a witness

chart with at least the following columns:

a. Serial Number

b. Name of the Witness

c. Brief Description/Role of the Witness, such

as: Informant, Eye-witness, Medical

Jurist/Doctor, Investigating Officer (I.O.),

Panch Witness, etc.

83.2. The description should be succinct but

sufficient to indicate the evidentiary character of the

witness. This structured presentation will allow quick

reference to the nature of testimony, assist in locating

the witness in the record, and minimize ambiguity.

83.3. Specimen Chart for Witnesses Examined

Prosecution

Witness No.

Name of

Witness

Description

1 Mr. X Eye-witness

2 Mr. Y Witness of last seen

circumstance

3 Ms. Z Medical Jurist

4 Mr. A Investigating Officer

5 Mr. B Complainant/First

Informant

84. Standardized Chart of Exhibited Documents

84.1 A separate chart shall be prepared for all

documents exhibited during trial. This chart shall

include:

a. Exhibit Number;

b. Description of document;

c. The Witness who proved or attested the

document.

84.2 Illustratively, the description may include:

FIR, complaint, panchnamas, medical certificates,

FSL reports, seizure memos, site plans, dying

declarations, etc.

84.3. The requirement of specifying the witness who

proved the document ensures traceability of proof

and assist the Court in appreciating compliance with

the Indian Evidence Act, 1872/Bharatiya Sakshya

Adhiniyam, 2023.

84.4. Specimen Chart for Exhibited Documents

Exhibit

No.

Description of the

Exhibit

Proved

by/Attested by

1 Inquest

Panchnama/Memo

PW-1

2 Recovery

Panchnama/Memo

PW-2

3 Arrest Memo PW-3

4 Post-mortem Report PW-4

5 FSL Report PW-5

85. Standardized Chart of Material

Objects/Muddamals

85.1 Whenever material objects are produced and

marked as exhibits, the trial Court shall prepare a

third chart with:

a. Material Object (M.O.) Number;

b. Description of the Object;

c. Witness who proved the Object’s Relevance

(e.g., weapon, clothing, tool, article seized

under panchnama, etc.)

85.2. This enables clarity regarding the physical

evidence relied upon.

85.3.Specimen Chart for Material

Objects/Muddamals

Material

Object No.

Description of the

Exhibit

Proved

by/Attested by

1 Weapon of Offence PW-1

2 Clothing of

accused/victim

PW-2

3 Mobile

Phone/Electronic

Object

PW-3

4 Vehicle PW-4

5 Purse/earrings/identity

card

PW-5

86. Special Provisions for Cases Involving

Voluminous Evidence

86.1. In complex cases, such as conspiracies,

economic offences or trials involving voluminous oral

or documentary evidence, the list of witnesses and

exhibits may be substantially long. Where the

number of witnesses or documents is unusually

large, the trial Court may prepare charts only for the

material, relevant, and relied-upon witnesses and

documents, clearly indicating that the chart is

confined to such items. This ensures that the charts

remain functional reference tools rather than

unwieldy compilations.

87. Application to Defence Witnesses and

Evidence

87.1. The aforesaid directions shall apply, mutatis

mutandis, to all witnesses examined and all evidence

adduced by the defence.

88. Adoption of Specimen Format and

Permissible Deviations

88.1. The specimen charts provided herein shall

ordinarily serve as the standard format to be followed

by trial Courts across the country.

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO(S). 2973 of 2023

MANOJBHAI JETHABHAI

PARMAR (ROHIT) Vs  STATE OF GUJARAT 

Author: Mehta, J.

Citation:  2025 INSC 1433.

Dated: DECEMBER 15, 2025.

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Bombay HC: What is importance of rule of chain of custody while appreciating DNA Evidence?

[VI] In Ananda Vs. The State of Maharashtra; MANU/MH/3781/2024 : 2024:BHC-AUG:11669-DB, one of the evidence was in the nature of DNA reports and it is observed as under :

"39. The question is, based on the DNA reports, whether the conviction and/or sentence passed by the trial court would be sustainable. We have gone through the impugned judgment. The trial court has relied on the evidence of each and every witness. It also relied on the evidence of the medical officer who collected blood of the appellant for DNA analysis, even in breach of protocol in that regard. The reason assigned for relying on the said evidence is that the said witness is uninterested and independent one. Before appreciating the evidence relating to DNA, we must have a look at the guidelines for collection, storage and transportation of the crime- scene DNA samples. Those have been placed on record by learned counsel for the appellant. Item No.10 therein speaks of maintaining the chain of custody. It describes what chain of custody means. Same reads as under:-

10. Maintaining the chain of custody:

• Chain of custody is a process used to maintain and document the chronological history of the evidence.

• A `chain of custody' document should be maintained which should include name or initials of the individual collecting the evidence, each person or entity subsequently having custody of it, dated the items were collected or transferred, agency and case number, victim's or suspect's name and the brief description of the item.

Those were the guidelines issued by The Central Forensic Science Laboratory, Chandigarh. PW 18 Vaishali admitted in cross-examination that the C.FS.L., Chandigarh and Hyderabad are best in India."

18. The relevant observations from the judgment in Kattavellai @ Devakar (supra) are reproduced as under :

DNA- A NECISSITATED ADDENDUM:

43. As we have discussed earlier in this judgment, the DNA evidence collected has been rendered unusable. It suffers from various shortcomings in as much as there is large amount of unexplained delay; the chain of custody cannot be established; possibility of contamination cannot be ruled out etc. 

44. This lack of a common procedure to be followed, is concerning. As such, we issue the following directions which shall be followed henceforth, in all cases where DNA Evidence is involved:

1. The collection of DNA samples once made after due care and compliance of all necessary procedure including swift and appropriate packaging including a) FIR number and date; b) Section and the statute involved therein; c) details of I.O., Police station; and d) requisite serial number shall be duly documented. The document recording the collection shall have the signatures and designations of the medical professional present, the investigating officer and independent witnesses. Here only we may clarify that the absence of independent witnesses shall not be taken to be compromising to the collection of such evidence, but the efforts made to join such witnesses and the eventual inability to do so shall be duly put down in record.

2. The Investigating Officer shall be responsible for the transportation of the DNA evidence to the concerned police station or the hospital concerned, as the case may be. He shall also be responsible for ensuring that the samples so taken reach the concerned forensic science laboratory with dispatch and in any case not later than 48- hours from the time of collection. Should any extraneous circumstance present itself and the 48-hours timeline cannot be complied with, the reason for the delay shall be duly recorded in the case diary. Throughout, the requisite efforts be made to preserve the samples as per the requirement corresponding to the nature of the sample taken.

3. In the time that the DNA samples are stored pending trial appeal etc., no package shall be opened, altered or resealed without express authorisation of the Trial Court acting upon a statement of a duly qualified and experienced medical professional to the effect that the same shall not have a negative impact on the sanctity of the evidence and with the Court being assured that such a step is necessary for proper and just outcome of the Investigation/Trial.

4. Right from the point of collection to the logical end, i.e., conviction or acquittal of the accused, a Chain of Custody Register shall be maintained wherein each and every movement of the evidence shall be recorded with counter sign at each end thereof stating also the reason therefor. This Chain of Custody Register shall necessarily be appended as part of the Trial Court record. Failure to maintain the same shall render the I.O. responsible for explaining such lapse.

The Directors General of Police of all the States shall prepare sample forms of the Chain of Custody Register and all other documentation directed above and ensure its dispatch to all districts with necessary instruction as may be required.

 IN THE HIGH COURT OF BOMBAY (AURANGABAD BENCH)

Criminal Appeal No. 821 of 2022, Criminal Application No. 3125 of 2025 in Criminal Appeal No. 821 of 2022

Ganesh Vs. The State of Maharashtra and Ors.

Hon'ble Judges/Coram:

Neeraj P. Dhote, J.

Decided On: 13.10.2025

Citation: 2025:BHC-AUG:28711,MANU/MH/6676/2025.

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Supreme Court: Whether executing court can examine validity of award of Lok Adalat and declare it as null and void?

 Legal Services Authorities Act, 1987; Sections 21 and 22E — Challenge to Lok Adalat Award — Maintainability of Writ Petition — Held, the statutory finality attached to a Lok Adalat award leaves no room for an appellate or plenary civil remedy - The validity of such an award cannot be reopened through an ordinary civil suit or by treating execution proceedings as a vehicle for setting it aside - The only recognized avenue of challenge is the constitutional jurisdiction of the High Court under Articles 226 or 227 of the Constitution of India, which is supervisory and exceptional in nature - This applies equally to a party to the award and a third party affected by it. [Relied on State of Punjab v. Jalour Singh, (2008) 2 SCC 660; Bhargavi Constructions v. Kothakapu Muthyam Reddy, (2018) 13 SCC 480; Paras 8-14]

Code of Civil Procedure, 1908; Order XXI Rules 97, 99, and 101 — Powers of Executing Court regarding Lok Adalat Awards — Held, while these provisions enable an Executing Court to address incidental questions during execution (such as the extent of enforceability against a person in possession), they do not authorize the court to examine the validity of the award itself or declare the decree based upon it void - The Executing Court has no authority to annul or set aside a decree that embodies a Lok Adalat award, nor can it sit in judgment over the validity of the compromise. Filing objections in execution cannot be treated as an "efficacious alternative remedy" that bars writ relief. [Paras 15-19]

IN THE SUPREME COURT OF INDIA 

CIVIL APPELLATE JURISDICTION 

SLP (C) No. 27806 of 2023; 

DILIP MEHTA Vs RAKESH GUPTA & ORS.

Coram: VIKRAM NATH; J., SANDEEP MEHTA; J. 

Dated: NOVEMBER 18, 2025 

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Supreme Court: Whether the court should decline bail to an accused on the ground that the co-Accused who was released on bail has not surrendered ?

After hearing learned Counsel for the parties, we are of the view that the fact that the co-Accused who was released on bail has not surrendered cannot be a germane factor to decline bail to the co-Accused, namely, the Appellant. {Para 8

 IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 1578 of 2023

Decided On: 18.05.2023

Sebil Elanjimpally Vs. The State of Odisha

Hon'ble Judges/Coram:

K.M. Joseph and Arun Kumar, JJ.

 Citation: 2023 INSC 557, MANU/SC/0615/2023

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