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Rajeev Singh v. State of Uttar Pradesh

Criminal Appeal · 2026 INSC 938Decided 31 Aug 2026
Crl.A. No.-004109-004109 - 2026
Justice Dipankar Datta · Justice Sheel Nagu

Background

The appellants were named in an FIR under the SC/ST Act and IPC but were not charge-sheeted after investigation. During trial, the complainant applied under Section 319 CrPC to have them summoned to face trial, and the Special Judge allowed this. The Allahabad High Court's Single Judge dismissed the appellants' appeal against that summoning order in a brief, eight-paragraph order giving no real reasons. The appellants challenged this before the Supreme Court.

Decision Breakdown

The Supreme Court held that the High Court's order was "laconic" and failed to meet the basic minimum standard expected of a reasoned judicial order - it merely recited that there was "no illegality or perversity" without referring to any evidence justifying the summoning. Citing its earlier ruling in Asma Lateef v. Shabbir Ahmad and the Constitution Bench test in Hardeep Singh v. State of Punjab for summoning additional accused, the Court found the High Court never explained what evidence, if any, satisfied that test. The Court quashed the High Court's order and remanded the criminal appeal for fresh, reasoned disposal.

Lesson Learnt

Every judicial order, however brief the compulsions of a heavy workload, must disclose the reasons for its conclusion - a bare "no illegality found" affirmation, without engaging the evidence, is not a valid judgment and can be set aside for that reason alone.

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

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