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Mukesh Singh v. State (Narcotic Branch of Delhi)

Special Leave Petition (Criminal) · 2020 INSC 524Decided 31 Aug 2020
Special Leave Petition (Criminal) No. 5648 of 2019
Justice Arun Mishra · Justice Indira Banerjee · Justice Vineet Saran · Justice M.R. Shah · Justice S. Ravindra Bhat

Background

This Constitution Bench judgment answers a referred question; it does not decide this petition itself. The question was whether, as Mohan Lal v. State of Punjab held, a criminal trial is automatically vitiated when the same police officer is both the informant and the investigator.

Decision Breakdown

This is not a final judgment in this petition. The five-judge bench overruled Mohan Lal and held there is no blanket rule; bias must be shown on the facts of each case. It directed that the individual petitions be decided on merits by the appropriate bench.

Lesson Learnt

A trial is not void just because the informant and investigator are the same officer; bias must be proved on the facts.

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

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