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State of Haryana v. Rajesh Aggarwal & Anr.

Criminal Appeal · 2018 INSC 722Decided 20 Aug 2018
Criminal Appeal No. 2218 of 2011
Justice Abhay Manohar Sapre · Justice Sanjay Kishan Kaul

Background

A blast occurred at a chemical drug factory in Gurgaon owned by a private company, causing a stampede among workers that killed seven of them. An FIR for murder (Section 302 IPC) was registered against the company's directors/shareholders, who were responsible for running the factory. The accused challenged the FIR in the Punjab and Haryana High Court, which partly allowed their petition and altered the charge from murder to the lesser offence of causing death by negligence (Section 304-A IPC). The State of Haryana appealed to the Supreme Court seeking restoration of the murder charge.

Decision Breakdown

The Supreme Court found no merit in the State's appeal and upheld the High Court's reasoning for altering the charge to Section 304-A IPC, noting this view could not be faulted at this stage. The Court expressed concern that the criminal trial had been stayed for years because of this litigation, unfairly benefiting the accused, and directed the Sessions Judge to complete the trial on merits within one year, while clarifying the trial court retained full power to alter or add charges later based on the evidence actually led. The appeal was dismissed and the interim stay on the trial was recalled.

Lesson Learnt

An appellate court's decision on which specific charge should be framed at a preliminary stage does not freeze the case forever: the trial court can still amend the charge later if the evidence presented during trial justifies it, and courts actively discourage prolonged delays caused by interim litigation.

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

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