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Chhote Lal vs. State of NCT of Delhi and Anr.

Criminal Miscellaneous Case · 2026:DHC:7410Decided 1 Sept 2026New Delhi Bench
CRL.M.C. 2176/2024CNR: DLHC010139432024
Justice Manoj Jain

Background

The petitioner, facing trial under Sections 354A/354D IPC and Section 12 of the POCSO Act, sought to have the child victim recalled for further cross-examination, arguing that her original cross-examination by a legal-aid lawyer was extremely sketchy. The trial court had dismissed this request.

Decision Breakdown

The High Court noted the cross-examination was indeed cursory, that the respondent (the victim, now presumably adult) had failed to respond despite being served twice, and that the case was still at the pre-final stage. Balancing fair-trial rights against finality, the Court directed the trial court to recall the victim (PW-1) for one further, effective round of cross-examination only, and imposed a cost of Rs. 2,000 on the petitioner payable to the witness.

Lesson Learnt

Courts can allow a limited, one-time recall of a witness for fair cross-examination where the original examination was inadequate, but will guard against misuse by capping it to a single further opportunity and imposing costs.

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