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Manjeet Singh v. State of Haryana & Ors.

Criminal Appeal · 2021 INSC 419Decided 24 Aug 2021
Criminal Appeal No. 875 of 2021
Dr. Justice D.Y. Chandrachud · Justice M.R. Shah

Background

Manjeet Singh and his cousin Amarjit Singh were attacked while driving home; Amarjit was shot dead and Manjeet was injured. The FIR named several people, but after investigation the police charge-sheeted only the main shooter, Sartaj Singh, and placed four other named persons (the private respondents) in "column 2", meaning they were not sent for trial. During the trial, when Manjeet Singh (the injured eye-witness) gave his evidence naming all the attackers again, he applied under Section 319 CrPC to have the four additional persons summoned to face trial. Both the trial court and the High Court refused this request.

Decision Breakdown

The Supreme Court held that the trial court and High Court were wrong to refuse the application. It reaffirmed settled law (from Hardeep Singh v. State of Punjab and later cases) that a court can summon additional accused under Section 319 CrPC even on the basis of an injured eye-witness's examination-in-chief alone, without waiting for cross-examination, and even if those persons were never charge-sheeted. The Court found that the four private respondents were specifically named in the FIR with distinct roles (carrying weapons, blocking the road), and that the police's decision to exonerate them was not based on any real investigation or witness testimony. The lower courts had wrongly evaluated the merits of the evidence at this preliminary stage, which is not permitted. The appeal was allowed and the trial court was directed to summon the four persons to face trial.

Lesson Learnt

A victim or witness who names specific attackers in an FIR and again in sworn testimony is not without recourse just because the police did not charge-sheet those persons: courts have the power to add them as accused at any stage before judgment, based on credible witness evidence.

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

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