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Central Bureau of Investigation vs Narottam Dhakad & Anr.

Criminal Appeal · 2023 INSC 770Decided 25 Aug 2023
Criminal Appeal No. 2592 of 2023
Abhay S. Oka · Rajesh Bindal · Pankaj Mithal as the second judge

Background

Two accused in the Madhya Pradesh VYAPAM examination-fraud scandal, charge-sheeted by the CBI in English, asked trial courts to direct that the charge sheet be translated into Hindi (the notified language of Madhya Pradesh's criminal courts), arguing they could not understand English. Trial courts rejected this, finding both accused educated and represented by English-speaking lawyers, but the Madhya Pradesh High Court ruled in the accused's favour in both cases, holding charge sheets must be filed in the court's language. The CBI appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that Section 272 of the CrPC (which lets a State fix the language of its courts) governs court proceedings, not the language in which investigating agencies must file their police reports/charge sheets under Section 173: no CrPC provision mandates that. Even if a charge sheet is filed in a language the accused doesn't understand, this does not automatically vitiate the proceedings; the test is whether it caused an actual failure of justice, and translation should be provided where the accused (and his advocate) genuinely cannot understand the language, especially given how easily AI translation tools now make this possible. Since both accused here were found to be educated in English and represented by English-conversant lawyers, no prejudice or failure of justice was shown, so the CBI's appeals succeeded and the High Court's orders were set aside.

Lesson Learnt

An accused person does not have an absolute right to a translated charge sheet purely because it is not in the court's official language: the real question is whether the accused was actually prejudiced in defending himself; if he or his lawyer can understand the document, no automatic right to translation arises.

Official source (sci.gov.in)View Judgment (PDF)

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