Showing posts with label Evidence. Show all posts
Showing posts with label Evidence. Show all posts

Sunday, August 3, 2025

Child Witness and His Evidence in Criminal Cases : Law Clarified by HC

Child Witness and His Evidence in Criminal Cases : Law Clarified by HC

It has been held in Pramjeet @ Sanni v. State [2025] GCtR 1383 (Delhi) that "one of the cardinal principles to be borne in mind, while assessing the acceptability of the evidence of a child witness, is that due respect has to be accorded to the sensibility and sensitivity of the Trial Court, on the issue of reliability of the child, as a witness in the case, as such decision essentially turns on the observation, by the Trial Court itself, regarding the demeanour and maturity of the concerned child witness. An appellate court would interfere, on this issue, only where the records make it apparent that the Trial Court erred in regarding the child as a reliable witness." 

Despite the argument on behalf of accused that there was prior enmity between victim's family and the accused, the conviction of accused was found to be proper. 

Thursday, July 17, 2025

DNA Evidence and Legal Principles : Recent Decision Explains

DNA Evidence and Legal Principles : Recent Decision Explains

In the recent case of KATTAVELLAI @ DEVAKAR v State of TN [2025] GCtR 1346 (SC) it was held that "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."



Wednesday, May 15, 2024

Dying Declaration and Tutoring : Supreme Court Explains The Law

Dying Declaration and Tutoring : Supreme Court Explains The Law 

"Court has to scrutinize the dying declaration carefully and must ensure that the declaration is not the result of tutoring, prompting or imagination; the deceased should be in a fit and proper state to make the declaration. But once the court is satisfied that the dying declaration is true and voluntary, it can base conviction on it without corroboration."

Refer Rajendra V. State of Maharashtra [2024] GCtR 1362 (SC)

Download Full text Judgment Free of cost from this link : - 

https://www.linkedin.com/feed/update/urn:li:activity:7196740491994918913/ 


Written by 

Vishal

Delhi

Notice : Copyright of above blog and its content including headline vests with Vishal. Above should Not be reproduced in any form in newspapers/websites/Ph.D. thesis/College projects/ law firms' newsletters/law journals/books/book chapters/blogs without prior written permission. Fair use should be in terms of Copyright Act, 1957. Any violation will make violator liable for Pecuniary compensation with interest towards the author irrespective of the profit made by the violator. All disputes shall be subject to Delhi Jurisdiction. Reproduction of judgment or publication of judgment unless expressly prohibited by Court according is not an infringement of copyright according to S. 52 (1)(q)(iv) of Copyright Act, 1957. This is not to be considered as any professional legal advice and does not constitute client-attorney relationship.

Saturday, May 11, 2024

Supreme Court Explains S.161 of Code of Criminal Procedure, 1973

Supreme Court Explains S.161 of Code of Criminal Procedure, 1973

"The statements under Section 161 of Code of Criminal Procedure, 1973 recorded during the investigation are not substantive pieces of evidence".

V.K. Mishra v. State of Uttarakhand [2015] GCtR 596 (SC)


Written by 

Vishal

Delhi

Notice : Copyright of above blog and its content including headline vests with Vishal. Above should Not be reproduced in any form in newspapers/websites/Ph.D. thesis/College projects/ law firms' newsletters/law journals/books/book chapters/blogs without prior written permission. Fair use should be in terms of Copyright Act, 1957. Any violation will make violator liable for Pecuniary compensation with interest towards the author irrespective of the profit made by the violator. All disputes shall be subject to Delhi Jurisdiction. Reproduction of judgment or publication of judgment unless expressly prohibited by Court according is not an infringement of copyright according to S. 52 (1)(q)(iv) of Copyright Act, 1957. This is not to be considered as any professional legal advice and does not constitute client-attorney relationship. 

Wednesday, May 8, 2024

Criminal Law : Important Decisions of 2024 - Part 1

 Criminal Law : Important Decisions of 2024 - Part 1


There have been many old yet important decisions on criminal law like Lalita Kumari v. Govt of UP [2013] GCtR 210 (SC), Y.S. Jagan Mohan Reddy v. CBI [2013] GCtR 338 (SC) and State of Haryana v. Bhajan Lal [1990] 4534 (SC).

Here are few important decisions of the year 2024 dealing with criminal law.


Section 45(1) of PMLA, 2002 lists the twin conditions that must be satisfied before an accused in case of money laundering can be enlarged on bail. -  Dalip Jindal v. ED [2024] GCtR 1291 (Delhi)

For attracting Section 141 of the NI Act, 1881 the primary responsibility of the complainant is to make specific averments in the complaint so as to make the accused vicariously liable.  - Himanshu Chopra v. State [2024] GCtR 393 (Delhi)

Though the Courts must be slow in exercising their jurisdiction under Section 482 of Code of Cr.P., 1973 for quashing the proceedings arising out of offences punishable under Section 307/308 IPC, the High Courts are not deprived of exercising the powers under Section 482 in certain special circumstances. - Mohd. Waseem v. State GNCTD [2024] GCtR 1292 (Delhi)

Even if custodial interrogation is not required or necessitated, the same by itself cannot be a ground to grant anticipatory bail. - Nitin Kumar Tomar v. State GNCTD [2024] GCtR 1293 (Delhi)

At the stage of granting bail, a detailed examination of evidence and elaborate documentation of the merit of the case need not be undertaken. - Ramesh Kakkar v. State of NCTD [2024] GCtR 1294 (Delhi)

Section 91 of Code of Criminal Procedure, 1973 can be invoked for production of documents or other things by way of issuance of summons.  - B. Sambi Reddy v. CBI [2024] GCtR 1295 (Delhi)


Written by 

Vishal

Delhi

Notice : Copyright of above blog and its content including headline vests with Vishal. Above should Not be reproduced in any form in newspapers/websites/Ph.D. thesis/College projects/ law firms' newsletters/law journals/books/book chapters/blogs without prior written permission. Fair use should be in terms of Copyright Act, 1957. Any violation will make violator liable for Pecuniary compensation with interest towards the author irrespective of the profit made by the violator. All disputes shall be subject to Delhi Jurisdiction. Reproduction of judgment or publication of judgment unless expressly prohibited by Court according is not an infringement of copyright according to S. 52 (1)(q)(iv) of Copyright Act, 1957. This is not to be considered as any professional legal advice and does not constitute client-attorney relationship. 




Saturday, January 20, 2024

Bharatiya Sakshya Adhiniyam, 2023 : Some Important Features

 Bharatiya Sakshya Adhiniyam, 2023 : Some Important Features


S.2 (b) says "conclusive proof" means when one fact is declared by said Adhiniyam to be conclusive proof of another, the Court shall, on proof of the one fact, regard the other as proved, and shall not allow evidence to be given for the purpose of disproving it.

Sec. 20 says oral admissions as to the contents of a document are not relevant, unless and until the party proposing to prove them shows that he is entitled to give secondary evidence of the contents of such document under the rules hereinafter contained, or unless the genuineness of a document produced is in question.

A criminal trial or inquiry shall be deemed to be a proceeding between the prosecutor and the accused within the meaning of S.27 of BSA, 2023.

Sec. 34 of BSA, 2023 says that the existence of any judgment, order or decree which by law prevents any Court from taking cognizance of a suit or holding a trial, is a relevant fact when the question is whether such Court ought to take cognizance of such suit or to hold such trial.

S.113 says when the question is whether any person is owner of anything of which he is shown to be in possession, the burden of proving that he is not the owner is on the person who affirms that he is not the owner.

S.108 says when a person is accused of any offence, the burden of proving the existence of circumstances bringing the case within any of the General Exceptions in the Bharatiya Nyaya Sanhita, 2023 or within any special exception or proviso contained in any other part of the said Sanhita, or in any law defining the offence, is upon him, and the Court shall presume the absence of such circumstances.

S.102 says persons who are not parties to a document, or their representatives in interest, may give evidence of any facts tending to show a contemporaneous agreement varying the terms of the document.

S.93 says where any electronic record, purporting or proved to be 5 years old, is produced from any custody which the Court in the particular case considers proper, the Court may presume that the electronic signature which purports to be the electronic signature of any particular person was so affixed by him or any person authorised by him in this behalf.

Sec. 53 says no fact needs to be proved in any proceeding which the parties thereto or their agents agree to admit at the hearing, or which, before the hearing, they agree to admit by any writing under their hands, or which by any rule of pleading in force at the time they are deemed to have admitted by their pleadings:

Sec. 46 says in civil cases the fact that the character of any person concerned is such as to render probable or improbable any conduct imputed to him, is irrelevant, except in so far as such character appears from facts otherwise relevant.

Sec. 45 says whenever the opinion of any living person is relevant, the grounds on which such opinion is based are also relevant.

Written by 

Vishal

Delhi

Notice : Copyright of above blog and its content including headline vests with Vishal. Above should Not be reproduced in any form in newspapers/websites/Ph.D. thesis/College projects/ law firms' newsletters/law journals/books/book chapters/blogs without prior written permission. Fair use should be in terms of Copyright Act, 1957. Any violation will make violator liable for Pecuniary compensation with interest towards the author irrespective of the profit made by the violator. All disputes shall be subject to Delhi Jurisdiction. Reproduction of judgment or publication of judgment unless expressly prohibited by Court according is not an infringement of copyright according to S. 52 (1)(q)(iv) of Copyright Act, 1957. This is not to be considered as any professional legal advice and does not constitute client-attorney relationship.


Wednesday, January 17, 2024

Interesting Judgments on Criminal Law : A Collection

Interesting Judgments on Criminal Law : A Collection

During the course of education in law, Indian students even in India are encouraged to read things which have "international" flavour.  "International criminal law (ICL) constitutes the fusion of two legal disciplines: international law and domestic criminal law. While it is true that one may discern certain criminal law elements in the science of international law, it is certainly not the totality of these elements that make up the discipline of ICL." [International Criminal Law, Ilias Bantekas and Susan Nash, 2nd Edition, Cavendish Publishing Ltd]

The article is about nothing international. Utility of domestic criminal law will always triumph over international criminal law. The present article is a collection of domestic rulings on some interesting aspects of criminal law. 

In Md. Hasmat Ali v State of Assam [2017] GCtR 4339 (Gauhati) it has been held that "It is highly an improbable proposition that a father of a married daughter in an Indian society would allow her to carry illicit relationship with her paramour in the absence of her husband and would react indifferently when reported by his son-in-law."

It has been reiterated in Shyamal Das v State of Assam [2017] GCtR 4340 (Gauhati) that "mere abscondance of an accused does not lead to a firm conclusion of his guilty mind, as even an innocent man may abscond in order to evade arrest and such an action may be part of the natural conduct of the accused."

In Dandeswar Barman v State of Assam [2017] GCtR 4343 (Gauhati) it has been held that it is the golden principle of criminal jurisprudence that ocular evidence must always be given preference to the expert opinion even if the expert opinion does not support the ocular evidence.

In Raju Satwal @ Chowtal v State of Assam [2017] GCtR 4344 (Gauhati) it was noted that the recovery of the knife at the instance of the accused also operates as strong evidence against the accused.

In Satish Kumar Kalra v CBI [2017] GCtR 1138 (Gauhati) it has been held that "the inherent power under Section 482 of the CrPC envisages three circumstances under which the inherent jurisdiction may be exercised, namely (i) to give effect under the Code (ii) to prevent abuse of process of court and (iii) otherwise to secure the ends of justice. The rule of inherent power has its source in the maxim “quando alique, concebit conceditur id sine quo resipsa esse non protest”, which means that when the law gives a person anything, it gives him that without which thing itself cannot exist. While exercising the power under the Section the court does not function as a court of appeal or revision."

It has been held in Mst. Maherun Nessa v State of Assam [2017] GCtR 4341 (Gauhati) that "it is well settled that in a case of circumstantial evidence, the prosecution must establish all the circumstances by independent evidence and the circumstances so established must form a complete chain in proof of guilt of the accused beyond reasonable doubts. The circumstances so proved must also be consistent only with the guilt of accused."

In Ripon Mollah v State of Assam [2017] GCtR 4307 (Gauhati) it was held that ordinarily it is not open to the High Court when there is concurrent finding of facts to interfere in its revisional jurisdiction, unless it is shown that the evidence on record was misread or misinterpreted by the courts below.

In Rocky Kalandi v State of Assam [2017] GCtR 4342 (Gauhati)doctor has also not opined that the head injury was possibly caused by some weapon ; the conviction under S.302, IPC was converted to the one under S.304 Part II of IPC, 1860. 


Written by 

Vishal

Delhi

Notice : Copyright of above blog and its content including headline vests with Vishal. Above should Not be reproduced in any form in newspapers/websites/Ph.D. thesis/College projects/ law firms' newsletters/law journals/books/book chapters/blogs without prior written permission. Fair use should be in terms of Copyright Act, 1957. Any violation will make violator liable for Pecuniary compensation with interest towards the author irrespective of the profit made by the violator. All disputes shall be subject to Delhi Jurisdiction. Reproduction of judgment or publication of judgment unless expressly prohibited by Court according is not an infringement of copyright according to S. 52 (1)(q)(iv) of Copyright Act, 1957. This is not to be considered as any professional legal advice and does not constitute client-attorney relationship.





Tuesday, January 9, 2024

Criminal Law : 10 Important Judgments of Supreme Court on Criminal Law

Criminal Law : 10 Important Judgments of Supreme Court on Criminal Law 


There are many important judgments. 

10 important Judgments on criminal law of Hon'ble Supreme Court are as follows : - 

1. Lalita Kumari v Govt of UP [2013] GCtR 210 (SC) - Scope of preliminary inquiry is not to verify the veracity or otherwise of the information received but only to ascertain whether the information reveals any cognizable offence.

2. Shabnam v State of UP [2015] GCtR 905 (SC)The act of slaughtering a ten month old child by strangulation in no chance reflects immature action but evidence for the lack of remorse, kindness and humanity.

3. Y.S. Jagan Mohan Reddy v CBI [2013] GCtR 751 (SC)Economic offences constitute a class apart and need to be visited with a different approach in the matter of bail.

4. Ram Singh v Sonia [2007] GCtR 3205 (SC) - Extra-judicial confession made even to a stranger cannot be eschewed from consideration if it is found to have been truthful and voluntarily made before a person who has no reason to state falsely.

5. State of Punjab v DPS Bhullar [2011] GCtR 4293 (SC) - There is no power of review with the Criminal Court after judgment has been rendered. The High Court can alter or review its judgment before it is signed.

6. Kailash Gour v State of Assam [2011] GCtR 4294 (SC) - The prosecution it is axiomatic, must establish its case against the accused by leading evidence that is accepted by the standards that are known to criminal jurisprudence regardless whether the crime is committed in the course of communal disturbances or otherwise.

7. Shivlal v State of Chhattisgarh [2011] GCtR 4295 (SC) - The Magistrate must be immediately informed of every serious offence so that he may be in a position to act under Section 159 of Code of Criminal Procedure , if so required.

8. Prithipal Singh v State of Punjab [2011] GCtR 2340 (SC) - In view of the provisions of Article 21 of the Constitution, any form of torture or cruel, inhuman or degrading treatment is inhibited. Torture is not permissible whether it occurs during investigation, interrogation or otherwise.

9. Pyla Mutyalamma @ Satyavathy v Pyla Suri Demudu [2011] GCtR 4296 (SC)The High Court under its revisional jurisdiction is not required to enter into reappreciation of evidence recorded in the order granting maintenance; at the most it could correct a patent error of jurisdiction.

10. W. Kalyani v State [2011] GCtR 4297 (SC) - From a plain reading of the Section 497 of IPC, 1860 it is seen that only a man can be proceeded against and punished for the offence of adultery. Indeed, the Section provides expressly that the wife cannot be punished even as an abettor.


Written by 

Vishal

Delhi

Notice : Copyright of above blog and its content including headline vests with Vishal. Above should Not be reproduced in any form in newspapers/websites/Ph.D. thesis/College projects/ law firms' newsletters/law journals/books/book chapters/blogs without prior written permission. Fair use should be in terms of Copyright Act, 1957. Any violation will make violator liable for Pecuniary compensation with interest towards the author irrespective of the profit made by the violator. All disputes shall be subject to Delhi Jurisdiction. Reproduction of judgment or publication of judgment unless expressly prohibited by Court according is not an infringement of copyright according to S. 52 (1)(q)(iv) of Copyright Act, 1957. This is not to be considered as any professional legal advice and does not constitute client-attorney relationship.  





Monday, April 3, 2023

Cross examination of Witness : Some Legal Issues

 Cross examination of Witness : Some Legal Issues 


There are different kinds of witnesses.


An important view on cross examination was stated by Lord Herschell, L.C. in Browne v. Dunn [(1893) 6 R 67] : - 


"I cannot help saying, that it seems to me to be absolutely essential to the proper conduct of a cause, where it is intended to suggest that a witness is not speaking the truth on a particular point, to direct his attention to the fact by some questions put in cross examination  showing that that imputation is intended to be made, and not to take his evidence and pass it by as a matter altogether unchallenged, and then, when it is impossible for him to explain, as perhaps he might have been able to do if such questions had been put to him, the circumstances which, it is suggested, indicate that the story he tells ought not to be believed, to argue that he is a witness unworthy of credit. My Lords, I have always understood that if you intend to impeach a witness, you are bound, whilst he is in the box, to give an opportunity of making any explanation which is open to him; and, as it seems to me, that is not only a rule of professional practice in the conduct of a case, but it is essential to fair play and fair dealing with witnesses."


Written by 

Vishal

Delhi

Notice : Copyright of above blog and its content including headline vests with Vishal. Above should Not be reproduced in any form in newspapers/websites/Ph.D. thesis/College projects/ law firms' newsletters/law journals/books/book chapters without prior written permission. Fair use should be in terms of Copyright Act, 1957. Any violation will make violator liable for Pecuniary compensation with interest towards the author irrespective of the profit made. All disputes shall be subject to Delhi Jurisdiction.     

Tuesday, March 14, 2023

On Cross-examination : A Legal Issue

 On Cross-examination : A Legal Issue 


An interesting finding was given. 

Lord Herschell, L.C. in (1893) 6 R 67 Browne v. Dunn stated thus : -


"I cannot help saying, that it seems to me to be absolutely essential to the proper conduct of a cause, where it is intended to suggest that a witness is not speaking the truth on a particular point, to direct his attention to the fact by some questions put in cross-examination showing that that imputation is intended to be made, and not to take his evidence and pass it by as a matter altogether unchallenged, and then, when it is impossible for him to explain, as perhaps he might have been able to do if such questions had been put to him, the circumstances which, it is suggested, indicate that the story he tells ought not to be believed, to argue that he is a witness unworthy of credit. My Lords, I have always understood that if you intend to impeach a witness, you are bound, whilst he is in the box, to give an opportunity of making any explanation which is open to him; and, as it seems to me, that is not only a rule of professional practice in the conduct of a case, but it is essential to fair play and fair dealing with witnesses."


Kindly note that full text Judgments of Hon'ble Supreme Court can be downloaded absolutely free of cost from the official website at the link https://main.sci.gov.in/judgments - Then entering the date of Judgment.


Written by 

Vishal

Delhi

Notice : Copyright of above blog and its content including headline vests with Vishal. Above should Not be reproduced in any form in newspapers/websites/Ph.D. thesis/College projects/ law firms' newsletters/law journals/books/book chapters without prior written permission. Fair use should be in terms of Copyright Act, 1957. Any violation will make violator liable for Pecuniary compensation with interest towards the author irrespective of the profit made. All disputes shall be subject to Delhi Jurisdiction.  

Scope of Section 9 of Arbitration and Conciliation Act, 1996 Answered in a recent Judgment passed in July 2026

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