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Lakhan Singh vs Amarjeet Singh & Anr.

Not available · 2022 INSC 1327Decided 6 Dec 2022
Not available
Dinesh Maheshwari · Sudhanshu Dhulia

Background

The complainant in a 2011 murder FIR (in which the accused, Amarjeet Singh, had been convicted and sentenced to life imprisonment) challenged a Delhi High Court order that let the accused introduce fresh medical evidence about his mental state, at the appeal stage, before the trial court. The accused had already contested his mental fitness once before, and the Supreme Court had earlier (in 2015) affirmed a trial court finding that he was fit to stand trial. The High Court's 2022 order treated the question of his mental state "at the time of the incident" as a separate, still-open issue and sent the file back to the trial court for more evidence.

Decision Breakdown

The Supreme Court set aside the High Court's order, holding it could not be sustained for several reasons: it failed to account for the Supreme Court's own 2015 order and the evidence already on record; and, more fundamentally, an appellate court cannot decide an application for additional evidence in a criminal appeal as a routine matter or before it has heard the appeal on merits. If further evidence was genuinely needed, the High Court itself (or its registry, under specific reasons) should have taken it, not remanded wholesale to the trial court without examining the record. The Court restored Criminal Appeal No. 453/2019 to the High Court for fresh consideration on merits, without commenting on the merits itself, and continued the existing interim arrangement until the parties' next appearance.

Lesson Learnt

An appellate court cannot let a party reopen settled questions of fact through open-ended "additional evidence" applications; such requests must be examined against the existing record and decided only after (or alongside) a proper hearing on the appeal's merits, not used as a shortcut to relitigate issues already concluded by a higher court.

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

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