Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Criminal LawSupreme Court of India

Devendra Kumar Pal vs State of U.P. & Anr.

Not available · 2024 INSC 679Decided 6 Sept 2024
Not available

Background

In a murder trial under Section 302 IPC, the trial court, on 21 March 2012, first pronounced convictions for some accused and acquittals for others. Later the same day, after already passing sentencing orders on the convicted accused, the trial court invoked Section 319 CrPC to summon Devendra Kumar Pal as an additional accused. Pal's challenge to this summoning order was dismissed by a Single Judge of the Allahabad High Court, and he appealed to the Supreme Court.

Decision Breakdown

The Supreme Court applied the Constitution Bench ruling in Sukhpal Singh Khaira v. State of Punjab (2022 INSC 1252), which held that the power under Section 319 CrPC must be exercised before the order of sentence (in case of conviction) or before the order of acquittal: a summoning order passed after sentence or acquittal is not sustainable. Since the trial court here had already passed the sentencing order before summoning Pal under Section 319, the summoning order fell foul of this rule. Bound by the Constitution Bench's law, the two-judge Bench allowed the appeal and quashed both the High Court's order and the trial court's summoning order against Pal.

Lesson Learnt

A court cannot add a new accused to a trial under Section 319 CrPC once it has already pronounced sentence (or acquittal) for the other accused: the timing of such an order is strict, and getting it wrong voids the summoning even if the underlying evidence might otherwise justify it.

Devendra Kumar Pal vs State of U.P. & Anr. – Legal Case Shots | LegalAware