Saturday, 4 October 2025

Supreme Court: Trial Court Cannot Take Cognizance Of Offence Not Mentioned In Chargesheet Only Based On Private Witness's Affidavit

 After giving due consideration to the issue at hand, we find

that the impugned order needs interference. The Court at the

outset, would make it clear that in principle, there is no quarrel

to the proposition that the Trial Court is within its powers to

alter the charge or to frame alternative charges. Further, the High

Court also has the power to direct for fresh consideration. In the

present case, we find that the manner in which the exercise has

been conducted is not in accordance with law. After the matter

being remanded by the High Court, it was incumbent upon the Trial Court to form a satisfaction of its own with regard to applicability of Section 394 of the IPC independently, based on the materials produced either by the complainant or by the defence and from the investigating agency or in the alternative to conduct the inquiry of its own. In the present case, when the allegation was that witnesses had made certain statements before the Police, which was recorded under Section 161 of the Code of Criminal Procedure, 1973 (for short, the “Cr.P.C.”), it was the duty of the prosecution to produce all such statements to the Court, which was not done. Then obviously, the Trial Court was required to call upon the Police to produce the entire case diary recording the complete statements of all the witnesses. Thereafter, upon perusing the same, especially, the portions which had not been forwarded to the Court earlier, the Trial Court could have formed an independent opinion as to whether ingredients of various Sections including Section 394 of the IPC were made out. This has not happened. In fact, only on the basis of affidavits of witnesses filed along with the petition on behalf of the complainant, the Court has taken cognizance under Section 394 of the IPC. We do not approve of such exercise in the manner it has been done. {Para 8}

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

 CRIMINAL APPEAL NO. OF 2025

 (Arising out of SLP(Crl.) No.6904 of 2025)

DEEPAK YADAV AND ANOTHER Vs STATE OF UTTAR PRADESH AND ANOTHER 

Dated: 17th SEPTEMBER, 2025.

Heard learned counsel for the parties.

2. Leave granted.

3. The appellants are aggrieved by the impugned order dated

11.11.2024 passed by the High Court of Judicature at Allahabad in

Application under Section 482 No.21222 of 2024, by which the High

Court has refused to interfere in the order dated 27.07.2023 passed

by the Special Judge, SC/ST Act, Jhansi in Special Case No.489 of

2018 where the Court has added Section 394 of the Indian Penal

Code, 1860 (for short, the “IPC”) in the charges framed against the

appellants.

4. Learned counsel for the appellants submitted that initially,

the FIR was registered under Sections 394, 452, 323, 504 and 506 of

the IPC and under Section 3(2)(v) of the Scheduled Castes and

Scheduled Tribes (Prevention of Atrocities) Act, 1989 (for short,

the “1989 Act”). However, the Police upon full

inquiry/investigation submitted the charge sheet under Sections

452, 323, 504 and 506 of the IPC and under Section 3(1)(D) of the

1989 Act where, Section 394 of the IPC was omitted. It was

submitted that the complainant-respondent no.2 had filed an

application before the Trial Court praying for addition of Charge

against the appellants under Section 394 of the IPC also. The same

was rejected and charges were framed under Sections other than

Section 394 of the IPC. This led to the complainant to move before

the High Court and the High Court had disposed of the matter with

liberty to the complainant to file an application before the Trial

Court for leading evidence and filing documents in support of his

contention. In the second round also, the Trial Court did not frame

charge under Section 394 of the IPC which again, prompted the

complainant to move before the High Court and the High Court again

remanded the matter to the Trial Court. It was submitted that in

the third round, the Trial Court has taken cognizance under Section

394 of the IPC also. Thereafter, the appellants moved before the

High Court against the said order, which was dismissed by the High

Court leading to filing of the present appeal.


5. It was submitted that the whole procedure adopted by the High

Court is totally unknown to law. It was further submitted that the

High Court while remanding the matter to the Trial Court, should

have remanded it with liberty to the Trial Court to go either for

fresh investigation by the Police or to conduct inquiry itself,

which has not been done and only based on the application which was supported by various affidavits filed on behalf of the complainant, cognizance has been taken. It was submitted that the requirement of law is not to take cognizance based only on the affidavits filed on

behalf of the complainant.

6. Learned counsel for respondent no.1-State submitted that the

Police after due investigation and based on the statement of

various witnesses had not found the matter covered under Section

394 of the IPC and thus consciously, Section 394 of the IPC was not

included in the charge sheet.

7. Learned counsel for respondent no.2-complainant submitted that

the FIR is of the year 2017 and still, it is at the stage of

framing of charge which shows that there are dilatory tactics on

the part of the accused-appellants. It was further submitted that

initially, when the complainant along with her two sons went to the

Police Station for lodging FIR, both the sons of the complainant

were beaten up and at the intervention of the Superintendent of

Police, the FIR was lodged and thus, the investigation besides

being one sided and motivated, even materials which had come during

investigation, were not fully put up before the Court and this

resulted in the Court not taking cognizance under Section 394 of

the IPC whereas, the fact is that witnesses had supported the

offence which would clearly, fall in the ambit of Section 394 of

the IPC.

8. After giving due consideration to the issue at hand, we find

that the impugned order needs interference. The Court at the

outset, would make it clear that in principle, there is no quarrel

to the proposition that the Trial Court is within its powers to

alter the charge or to frame alternative charges. Further, the High

Court also has the power to direct for fresh consideration. In the

present case, we find that the manner in which the exercise has

been conducted is not in accordance with law. After the matter

being remanded by the High Court, it was incumbent upon the Trial

Court to form a satisfaction of its own with regard to

applicability of Section 394 of the IPC independently, based on the

materials produced either by the complainant or by the defence and

from the investigating agency or in the alternative to conduct the

inquiry of its own. In the present case, when the allegation was

that witnesses had made certain statements before the Police, which

was recorded under Section 161 of the Code of Criminal Procedure,

1973 (for short, the “Cr.P.C.”), it was the duty of the prosecution

to produce all such statements to the Court, which was not done.

Then obviously, the Trial Court was required to call upon the

Police to produce the entire case diary recording the complete

statements of all the witnesses. Thereafter, upon perusing the

same, especially, the portions which had not been forwarded to the

Court earlier, the Trial Court could have formed an independent

opinion as to whether ingredients of various Sections including

Section 394 of the IPC were made out. This has not happened.

In fact, only on the basis of affidavits of witnesses filed along

with the petition on behalf of the complainant, the Court has taken

cognizance under Section 394 of the IPC. We do not approve of such

exercise in the manner it has been done.

9. For reasons aforesaid, the order taking cognizance against the

appellants is set aside. The matter is remanded to the Trial Court,

which is directed to call upon the Police to produce the entire

investigation and statements of the witnesses which has been

recorded. Further, if the Police has missed out recording the

statement of any of the witnesses, the affidavits of the witnesses

as furnished by the complainant shall be forwarded to the Police.

The Police shall then, carry further investigation and submit a

further report to the concerned Court. The same be done within six

weeks from today. Based upon that, the Court after hearing all

concerned, shall proceed to the stage of taking cognizance and

thereafter, framing of charge and proceeding with the trial, as the

case may be. We make it clear that we have not expressed any

opinion on the merits of the matter.

10. Learned counsel for respondent no.1-State shall communicate to

the Superintendent of Police, District Jhansi that investigation

should be free, impartial and there should not be any suppression

of any material which has come across during the investigation and

truthfully, the same shall be placed. We make it clear that the

Superintendent of Police, District Jhansi, shall be personally

liable if in future, it transpires that any material which has come

during investigation, was withheld from the concerned Court.

11. Accordingly, the appeal stands disposed of in the

aforementioned terms.

12. Pending application(s), if any, shall also stand disposed of.

 ……………………………………………………………………J.

 [AHSANUDDIN AMANULLAH]

…………………………………………………………………………J.

 [SATISH CHANDRA SHARMA]


NEW DELHI

17th SEPTEMBER, 2025


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