Introduction
The Supreme Court's judgment in Jitendra Kumar Rode v. Union of India represents a watershed moment in Indian criminal jurisprudence,
establishing a novel constitutional principle that elevates procedural
compliance from mere technicality to fundamental right. This case addresses the
substantial question of whether appellate courts can legitimately uphold
convictions without access to complete trial records, ultimately ruling that
such proceedings violate the constitutional guarantee of due process under
Article 21.
Background and Factual Matrix
The case emerged from a corruption prosecution dating back to 1995, when Jitendra Kumar Rode, an Assistant Commercial Manager with Northern Railway, was accused of accepting a ₹500 bribe from a Chief Ticket Inspector. The Special Judge convicted him in 1999 under Sections 7, 13(1), and 13(2) of the Prevention of Corruption Act, 1988, sentencing him to rigorous imprisonment and fines.
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