The Supreme Court of India has set aside the Punjab and Haryana High Court’s order that had quashed a Sessions Judge’s directive summoning additional accused in a criminal case not named in FIR. The case, Satbir Singh v. Rajesh Kumar and Others, involved charges under Sections 323, 324, 307, and 506 of the Indian Penal Code (IPC), along with Section 34 IPC and Section 25 of the Arms Act.
Factual Matrix
The case originated from an altercation on February 9, 2020, in Karnal, Haryana, where an argument over a volleyball game escalated into a violent confrontation. Satbir Singh, an army personnel on leave, was allegedly attacked by Mukesh and others. Mukesh was charged with stabbing Singh in the waist and near the heart in FIR, while the other accused were alleged to have assaulted him with wooden sticks and iron rods.
The initial investigation resulted in a closure report against four of the accused—Rajesh Kumar, Sagar @ Bittoo, Niraj, and Ankit—due to a lack of evidence. However, Singh later filed an application under Section 319 of the Criminal Procedure Code (CrPC), seeking to summon them for trial. The Sessions Judge granted the request, finding sufficient evidence against them, but the High Court later overturned this decision.
Supreme Court’s Findings
A bench comprising Justices Dipankar Datta and Manmohan ruled in favor of the appellant, reinstating the Sessions Judge’s order. The Court emphasized that Section 319 CrPC grants discretionary power to summon individuals not originally named as accused if evidence emerges indicating their involvement in the crime.
“The High Court failed to appreciate the essence of Section 319 CrPC. The Sessions Judge’s satisfaction, which was higher than a mere prima facie view, was based on the appellant’s testimony and medical records. The High Court’s interference was unwarranted,” the Supreme Court observed.
Accused not named in FIR can be Summoned Legal cases:
The Court relied on key precedents, including Hardeep Singh v. State of Punjab (2014) 3 SCC 92 and Jitendra Nath Mishra v. State of Uttar Pradesh (2023) 7 SCC 344. The rulings reaffirm that additional accused can be summoned if there is substantial evidence indicating their involvement.
In this case, the Sessions Judge had found that the appellant’s injuries, medical reports, and witness statements collectively justified summoning the additional accused. The Supreme Court underscored that such an order should not be overturned unless it is perverse or unreasonable.
Implications of the Verdict
With this decision, the Supreme Court has directed the Sessions Court to proceed with the trial expeditiously. The ruling strengthens the legal precedent that courts can summon additional accused if new evidence emerges, ensuring that all individuals allegedly involved in a crime are brought to trial.
Legal experts view this judgment as a reaffirmation of judicial discretion in criminal trials. It underscores that superior courts should be cautious in interfering with well-reasoned lower court decisions unless they are legally untenable.
The Supreme Court’s verdict reinstates the Sessions Judge’s order and sets aside the Punjab and Haryana High Court’s ruling. It reiterates the importance of examining evidence holistically and upholding the discretionary powers granted to trial courts under Section 319 CrPC.
This landmark ruling is expected to influence future cases where additional accused are summoned based on emerging evidence, reinforcing the principle that justice must be thorough and inclusive of all potential perpetrators.
