Criminal Procedure Code

Frequently Asked Questions on Criminal Procedure Code

Ans. History of Law of Procedure in Criminal Courts - Previous to 1882 there was no uniform law of Criminal procedure for the whole of India. There were separate Acts, mostly rudimentary in their character, to guide the procedure of numerous courts in provinces and in the Presidency-towns. These Acts of procedure were replaced by Act X of 1882 which was Code of Criminal Procedure 1882 (Act X) which gave for the first time a uniform law of procedure for whole of India and it was supplanted by a new Code in 1898.

The Code of Criminal Procedure 1898 underwent drastic amendments at the hands of legislature in 1923 and since 1923 changes were made from time to time by minor Amendment Acts.

The Code again underwent drastic amendments in 1955 by Code of Criminal Procedure (Amendment) Act 26 of 1955. Schemes for the separation of judicial and executive functions of Magistrate were introduced by State legislatures from time to time and the Code was amended accordingly.

There was a constant demand for the revision of the Code partly to simplify the procedure and partly to introduce a uniform system in the country in relation to Judicial and Executive functions of Magistrates. The Law Commission therefore submitted a revised draft for the Code in its 13th report and thereafter it had undergone some changes in the hands of the joint select committee of the Parliament, and was passed into present form in 1973

Important Changes to Act 2 of 1974 : Following changes were brought about with a view to speeding up the disposal of Criminal Cases:-

(i) The preliminary inquiry which precedes the trial by Court of Session, known as "Committal proceedings" was abolished.

(ii) the scope of summary trials was widened by including offences punishable with imprisonment upto one year instead of six months.

(iii) the power of revision against "interlocutory orders" was taken away.

(iv) the provisions for compulsory stoppage of proceedings by subordinate court on mere intimation from a party of his intention to move a higher court for transfer of the case was omitted.

(v) Provision was made for service of summons by registered post in certain cases.

(vi) Provisions for legal aid to indigent persons were made.

(vii) Courts have been empowered to order for payment of compensation by accused to victims of crime

Scope and Object of Code The object of the Criminal Procedure Code is to provide a machinery for the punishment of offenders against the sub stantive criminal law. It prescribes the procedure for the trial of offences which the Indian Penal Code defines. Section 4 of this Code provides that all offences under the Code shall be investigated, enquired into, tried and otherwise dealt with according to the provisions of this Code. It also provides that offences under a law other that the Indian Penal Code will also be tried according to the provisions of the Procedure Code, but subject to any provision in that other law in regard to investigation, inquiry or trial [Section 4(2)]. The Penal Code is thus the substantive law, of which the Procedure Code furnishes the adjective law to put in force its provisions. The Code is a code of procedure and, like all procedural laws, is designed to further the ends of justice and not to frustrate them by the introduction of endless technicalities. The object of the Code is to ensure that an accused person gets a full and fair trial along certain well-established and well-understood lines in accord with our notions of natural justice.

In Wilie Staney v. State of M.P., AIR 1956 SC 116, it was observed "The object of code is to ensure that accused person gets full and fair trial along certain well-established and well-understood lines that accord with our notions of natural justice, under the code as in all procedural laws, certain things are regarded as vital. Disregard of provisions of that nature is fatal to trial and at once invalidates the conviction. Other are not vital and what ever the irregularity, they can be cured. Chapter 45 of the code has carefully classified certain kinds of errors and expressly indicates how they are to be dealt with.

Ans. Cognizable and Non-Cognizable Offence Section 2(c) of Code define "Cognizable Offences and Cognizable Cases" as cognizable offence means offences for which and cognizable case means cases in which police officer may in accordance with first schedule of Criminal Procedure Code or under any other law for the time being in force arrest without warrant.

Then Section 2(l) of Code defines Non-Cognizable Offences and Non-Cognizable Cases as non-cognizable offence means offences for which and non-cognizable case means cases in which police officer has no authority to arrest without warrant.

So difference between cognizable and non-cognizable offences lies in the fact that in case of cognizable offence, a police officer can arrest without warrant whereas in Non-Cognizable offences police officer can not arrest any one without warrant.

Column 4 of First Schedule attached to the Code of Criminal Procedure mentions which are cognizable offences and which are non-cognizable offences. In case of commission of cognizable offence, if matter is reported to police, then police will record the First Information Report under Section 154 of Code and shall proceed to investigate the matter and arrest the accused without any warrant or Order of Magistrate. But in case of Non-Cognizable offence, police can not investigate without Order of Magistrate. Section 155 of Code provides procedure to be adopted by police in case of non-cognizable offences

Bailable and Non-Bailable Offences Section 2(a) of Code of Criminal Procedure defines `Bailable and Non-Bailable Offences' Section 2(a) says "Bailable offence means an offence which is shown as bailable in the first schedule or which is made bailable by any other law for the time being in force and non-bailable offence means any other offence.

Column 5 of first schedule in its first part mention which offence of Indian Penal Code is bailable and which is non-bailable. Second part of the first schedule of Code deals with offences, other than that of Indian Penal Code and provides that all those offences which are punishable with imprisonment for term of 7 years or more are non-bailable and all offences punishable with imprisonment for term of three years or more are also non-bailable but offence punishment of which is imprisonment for term less than three years are bailable.

Chapter XXXIII of Code contains provisions regarding bail. Section 436 of Code provides as to bail in bailable offences Bail in bailable offences is a matter of right. Then Section 437 of Code provides as to granting of bail by Magistrate in non-bailable offences . It also provides that Magistrate shall not grant bail in offence punishable with death or imprisonment for life. However in case of person less than 16 years of age or woman or sick or infirm person, Magistrate may grant bail even in case of offences punishable with imprisonment for life or with death. Then Section 438 of Code provides for Anticipatory bail and Section 439 of Code then provides for bail by Session Court or High Court in non-bailable offences

SUMMON AND WARRANT CASES Section 2(w) of Code says `Summons case', means a case relating to an offence and not being warrant case.

According to Section 2(x) `Warrant case' means a case relating to an offence punishable with death, imprisonment for life or imprisonment for term exceeding two years.

So offences punishable with death or imprisonment for life or imprisonment for term exceeding 2 years are warrant cases and any other cases are summons cases. Following are the points of difference between two:

(a) For trial of Warrant Case by Magistrate two procedures are prescribed. One is adopted by Magistrate in cases instituted on Police report (Sections 238 to 243 and 248 Cr.P.C.) and other is for case instituted otherwise than on police report ( Sections 244 to 250 Cr.P.C.). Whereas, there is only one procedure prescribed for trial of Summons Cases (Sections 251 to 259).

(b) Trial of Warrant Cases as Summons Cases is an irregularity which vitiates the trial if prejudice is caused to accused. But trial of Summons Cases as Warrant Cases is only curable irregularity within the meaning of Section 465 of Code.

(c) Where a Warrant Case is tried as Summons Case and accused is acquitted, then Order of acquittal will operate as discharge under Section 245 and where a summon case is tried as a Warrant Case and accused is discharged under Section 245, it will operate as Order of acquittal.

(d) In a Warrant Case, framing of charge is necessary, whereas in Summon Cases framing of charge against accused is not necessary.

Ans. Section 2(g) of Code of Criminal Procedure defines the term : "Inquiry" "Inquiry means every inquiry other than a trial conducted under this code by a Magistrate or Court."

Term "Inquiry" is wider than `b'. In V.C. Shukla v. State through C.B.I. AIR 1980 SC 962. The Supreme Court has held that from the time the accused appears or is produced before the Magistrate with the Police Report under Section 170 of Code and the Magistrate proceeds to enquire whether Section 207 of Code has been complied with and then proceeds to commit the accused to the court of Session, the proceedings before the Magistrate would be an inquiry as contemplated by Section 2(g) of the Code."

So "Inquiry" is a name given to a proceeding conducted under the Code of Criminal Procedure by a Magistrate or a Court, other than a trial for ascertaining or verifying facts with a view to take some action under the code. Ambit of Inquiry is very wide and comprehensive and include proceedings under Sections 340, 144, 145, 176, 446 of Cr.P.C.

Section 2(h) of Code define the expression "Investigation" as "Investigation includes all the proceedings under this code for the collection of evidence, conducted by Police Officer or by any person (other than Magistrate) who is authorized by a Magistrate in this behalf."

Supreme Court recently in Navin Chandra N. Majithia v. State of Meghalaya 2000(4) Recent Criminal Reports 476 has observed "The Code contemplates the following steps to be carried out during such investigation (1) Proceeding to spot (2) Ascertainment of the facts and circumstances of the case (3) Discovery and arrest of suspected offender (4) Collection of evidence relating to the commission of offence which may consist of (a) the examination of various persons (including accused) and reduction of their statement into writing (b) search of places, seizure of things considered necessary for investigation and to be produced at the trial. (5) Formation of opinion as to whether on material collected, there is a case to place the accused before Magistrate for trial and if so taking the necessary steps for the same by the filing of a charge sheet under Section 173."

DISTINCTION BETWEEN INQUIRY AND INVESTIGATION : An `Inquiry' relates to a proceeding held by a court or Magistrate while an `Investigation' relates to steps taken by a police officer or a person other than a Magistrate. The object of Inquiry is to determine `prima facie' the truth of falsity of certain facts in order to take further action thereon. Object of Investigation to ascertain the facts and collecting the evidence relating to commission of crime and to arrest the offender.

Term "Trial" has not been defined in the Code. Trial may be said to be a judicial proceeding which ends either in conviction or acquittal of the accused. If in a proceeding the court has no power to convict or acquit, it is no `trial'. Trial includes all steps which a criminal court adopts subsequent to the framing of charge and until the pronouncement of judgement.

INQUIRY AND TRIAL - DISTINCTION : Inquiry is the second stage of a criminal proceeding and is always to be conducted by a Magistrate. Term `Trial' is distinguished as an original judicial proceeding. A judicial proceeding in a criminal case which ends either in conviction or acquittal of the accused, is a proceeding in which evidence is or may be legally taken on oath. The proceedings in a summon case after the appearance of accused or in a warrant case, after the charge is drawn are trials . In criminal matters, the inquiry is something different from trial. `Inquiry stops when trial begins so all proceedings before Magistrate, before framing the charge which do not result in conviction or acquittal can be termed as `Inquiry'. Trial presupposes the idea of an offence. But inquiry relates or matters which are not offences .

Ans. Chapter II of Code and Sections 6 to 24 deal with the constitution of Criminal Courts. Section 6 of Code says -

Besides the High Courts and the Courts constituted under any law, other than this Code, there shall be, in every State, the following classes of Criminal Courts, namely :-

(i) Courts of Session;

(ii) Judicial Magistrates of the first class and, in any metropolitan area, Metropolitan Magistrates;

(iii) Judicial Magistrates of the second class; and

(iv) Executive Magistrates.

Then Section 7 of the Code says that every State shall consist of Session division and each Session division, for the purpose of this Code, shall be district or consist of districts. In substance provision under section 7 is the same as was provided in old code but as a result of separation of judicial functions of magistrate from those of executive consequential changes were brought. Then Section 8 of code says that State Government may by notification declare any area in the State, comprising a city or town whose population exceeds one million shall be metropolitan area and city of Ahmedabad declared to be metropolitan area. State Government have also been empowered to extend, reduce or alter the limits of metropolitan area.

Section 9 of Code says -

(1) The State Government shall establish a Court of Session for every sessions division.

(2) Every court of Session shall be presided over by a Judge, to be appointed by the High Court.

(3) The High Court may also appoint Additional Sessions Judges and Assistant Sessions Judges to exercise jurisdiction in a Court of Session.

(4) The Sessions Judge of one Sessions division may be appointed by the High Court to be also an Additional Sessions Judge of another division, and in such case he may sit for the disposal of cases at such place or places in the other division as the High Court may direct.

(5) Where the office of the Sessions Judge is vacant, the High Court may make arrangements for the disposal of any urgent application which is, or may be, made or pending before such Court of Session by an Additional or Assistant Sessions Judge, or, if there be no Additional or Assistant Sessions Judge, by a Chief Judicial Magistrate, in the sessions division; and every such Judge or Magistrate shall have jurisdiction to deal with any such application.

(6) The Court of Session shall ordinarily hold its sitting at such place or places as the High Court may, by notification, specify; but, if, in any particular case, the Court of Session is of opinion that it will tend to the general convenience of the parties and witness to hold its sittings at any other place in the sessions division, it may, with the consent of the prosecution and the accused, sit at that place for the disposal of the cases or the examination of any witness or witnesses therein.

So Section 9 deals with the power of State Government to establish Courts of Sessions and the power of High Court to appoint judges thereto and to direct at what places such courts shall hold its sittings. The State Government is bound to establish a Court of Session for every Sessions division then section 10 declares that all Assistant Sessions Judges shall be subordinate to Sessions Judge, who will time to time make rules as to distribution of business among such Assistant Sessions Judges.

Then Section 11 provides -

(1) In every district (not being a metropolitan area), there shall be established as many Courts of Judicial Magistrates of the first class and of the second class, and at such places, as the State Government may, after consultation with the High Court, by notification, specify:

Provided that the State Government may, after consultation with the High Court, establish, for any local area, one or more Special Courts of Judicial Magistrates of the first class or of the second class to try any particular case or particular class of cases, and where any such Special Court is established, no other court of Magistrate in the local area shall have jurisdiction to try any case or class of cases for the trial of which the such Special Court of Judicial Magistrate has been established.

(2) The presiding officers of such Courts shall be appointed by the High Court.

(3) The High Court may, whenever, it appears to be expedient or necessary, confer the powers of a Judicial Magistrate of the first class or of the second class on any member of the Judicial Service of the State, functioning as a Judge in a Civil Court.

The Section 12 says that in every district (not being a metropolitan area) High Court shall appoint a Judicial Magistrate of first class to be Chief Judicial Magistrate and Additional Chief Judicial Magistrate and Sub- divisional Judicial Magistrate. Then Section 13 of Code says that High Court upon the request of Central or State Government, confer upon any person who hold or has held any post under the Government all or any powers conferrable under the code to a Judicial Magistrate of first or second class for particular case or class of cases provided such person possesses such qualification and experience in legal affairs as High Court requires and such Magistrate shall be called "Special Magistrate" who will be appointed for term not exceeding one year at a time. Then section 14 of Code says subject to control of High Court, Chief Judicial Magistrate may from time to time define local jurisdiction within which Magistrates as appointed under section 11 or 13 may exercise any power as conferred under this Code. Then Section 15 says every Chief Judicial Magistrate shall be subordinate to Sessions Judge and every other Judicial Magistrate, shall be subject to general control of Sessions Judge be subordinate to Chief Judicial Magistrate who shall from title to time make rules or make order as to distribution of business among Judicial Magistrates.

Thereafter Sections 16, 17, 18 and 19 deal regarding Metropolitan Magistrate on similar provisions as stated above. Then section 20 says that in every District and Metropolitan area, the State Government may appoint any numbers of Executive Magistrates and one of them shall be appointed as District Magistrate. State Government may appoint an Executive Magistrate as Additional District Magistrate and may place any such executive magistrate in sub-division who shall be called `Sub-divisional Magistrate. Section 21 provides regarding appointment of Special Executive Magistrate. Then Section 22 says that subject to control of State Government, District Magistrate from time to time, may define local limits of jurisdiction of Executive Magistrates. All Executive Magistrates, other than Additional District Magistrate shall be subordinate to District Magistrate who will make rules regarding distribution of work among Executive Magistrate. (Section 23).

Power of Courts :- Chapter III of Codes deal with power of different criminal courts. Section 26 deals with the description of offences cognizable by several courts constituted under the Code. Section 26(a) says any offence of I.P.C. may be tried by

(i) High Court or

(ii) Court of Session or

(iii) any Judicial Magistrate by which such offence is shown in First Schedule, to be triable.

Section 26(b) says any offence under any other law shall be tried by court as mentioned in that law and when no such court is so mentioned, then it will be tried by

(i) High Court or

(ii) Court by which such offence is shown in First Schedule to triable.

Section 27 of Code then says about jurisdiction of court in case of Juveniles.

Then Section 28 says -

"(1) A High Court may pass any sentence authorised by law.

(2) A Sessions Judge or Additional Sessions Judge may pass any sentence authorised by law; but any sentence of death passed by such Judge shall be subject to confirmation by the High Court.

(3) Any Assistant Sessions Judge may pass any sentence authorised by law except a sentence of death or of imprisonment for life or of imprisonment for a term exceeding ten years."

Section 29 of Code says -

"(1) The Court of the Chief Judicial Magistrate may pass any sentence authorised by law except a sentence of death or of imprisonment for life or of imprisonment for a term exceeding seven years.

(2) The Court of a Magistrate of the first class may pass a sentence of imprisonment for a term not exceeding three years, or of fine not exceeding five thousand rupees, or of both.

(3) The Court of a Magistrate of the second class may pass a sentence of imprisonment for a term not exceeding one year, or of fine not exceeding one thousand rupees, or of both.

(4) The Court of a Chief Metropolitan Magistrate shall have the powers of the Court of a Chief Judicial Magistrate and that of a Metropolitan Magistrate, the powers of the Court of a Magistrate of the first class."

Then Section 30 says -

(1) The Court of a Magistrate may award such term of imprisonment in default of payment of fine as is authorised by law :

Provided that the term -

(a) is not in excess of the powers of the Magistrate under Section 29;

(b) shall not, where imprisonment has been awarded as part of the substantive sentence, exceed one-fourth of the term of imprisonment which the Magistrate is competent to inflict as punishment for the offence otherwise than as imprisonment in default of payment of the fine.

(2) The imprisonment awarded under this section may be in addition to a substantive sentence of imprisonment for the maximum term awardable by the Magistrate under Section 29.

Ans. Section 2(4) of Code says "Public Prosecutor" means any person appointed under section 24 and includes any person acting under the directions of Public Prosecutor.

Since in criminal cases State is in the prosecutor, the State is represented in the Court by the Public Prosecutor. In the High Courts and Court of Sessions the State Government is represented by Public Prosecutor and in the Court of Magistrate by the Assistant Public Prosecutor.

The provisions of the Criminal Procedure Code regarding the appointment of Public Prosecutors are contained in Section 24, which provides as herein under :-

(1) For every High Court, the Central Government, or the State Government shall, after consultation with the High Court, appoint a Public Prosecutor and may also appoint one or more Additional Public Prosecutors, for conducting in such Court, any prosecution, appeal or other proceeding on behalf of the Central Government or State Government, as the case may be.

(2) The Central Government may appoint one or more Public Prosecutors, for the purpose of conducting any case or class of cases in any district or local area.

(3) For every district, the State Government shall appoint a Public Prosecutor and may also appoint one or more Additional Public Prosecutors for the district :

Provided that the Public Prosecutor or Additional Public Prosecutor appointed for one district may be appointed also to be a Public Prosecutor or an Additional Public Prosecutor, as the case may be, for another district.

(4) The District Magistrate shall, in consultation with the Sessions Judge, prepare a panel of names of persons, who are in his opinion fit to be appointed as Public Prosecutors or Additional Public Prosecutors for the district.

(5) No person shall be appointed by the State Government as the Public Prosecutor or Addl. Public Prosecutor for the district unless his name appears in the panel of names prepared by the District Magistrate under sub-section (4).

(6) Notwithstanding anything contained in sub-section (5) where in a State there exists a regular Cadre of Prosecuting Officers, the State Government shall appoint a Public Prosecutor or an Addl. Public Prosecutor only from among the persons constituting such Cadre :

Provided that where, in the opinion of the State Government, no suitable person is available in such Cadre for such appointment, the Government may appoint a person as Public Prosecutor or Addl. Public Prosecutor, as the case may be from the panels of names prepared under sub- section (4).

(7) A person shall be eligible to be appointed as a Public Prosecutor or an Addl. Public Prosecutor under sub-section (1), (2) or (3) or (6), only if he is in practice as an advocate for not less than 7 years.

(8) The Central Government or the State Government may appoint for the purpose of any case or class of cases, a person who has been in practice for not less than ten years, as a Special Public Prosecutor.

(9) For the purpose of sub-sections (7) and (8), the period during which a person has been in practice as a pleader, or has rendered (whether before or after commencement of this Code) service as a Public Prosecutor or as an Addl. Public Prosecutor or as Assistant Public Prosecutor or other Prosecution Officer, by whatever name called, shall be deemed to be the period during which such person has been in practice as an advocate.

In State of Rajasthan v. Manohar, 1981(2) SCC 525, it was held that notification by State Government appointing Advocate General is to be public prosecutor under section 24 Criminal P.C. - Another Notification by Advocate General authorising law officers including Deputy Advocate General to act, plead and argue in all matters covered by code - Held - Deputy Advocate General was public servant.

In R. Sarala v. T.S. Velu and others, AIR 2000 SC 1731, it was observed that role of Public Prosecutor is inside the court and it commences after investigating agency presents the case in court after completion of investigation. Therefore, involving Public Prosecutor in investigation is injudicious and an investigating officer can not be directed to consult the Public Prosecutor before filling his report under section 173 Cr. P.C.

According to section 25 an Assistant Public Prosecutor is appointed to conduct prosecutions in the Courts of Magistrates. They are appointed by the State Government. No police officer is eligible for appointment as such but in a case for which no Assistant Public Prosecutor is available, the District Magistrate may appoint any other person to be Assistant may also be so appointed but such police officer should not be below the rank of an Inspector or and he should not have participated in the investigation of the case being prosecuted. A new sub-section (1-A) to Section 25 of the Code has been inserted by the Amendment Act, 1978, by which Central Government may also appoint Assistant Public Prosecutors for conducting cases in the Court of Magistrate.

In S.B. Shane v. State, AIR 1995 SC 1628, it was observed that according to section 25 there is statutory obligation imposed on the state or Central Government to appoint one or more Asst. Public Prosecutors in every district for conducting prosecutions in the Magistrate Courts and of making such Assit. Public Prosecutors independent of the Police Department by constituting separate cadre of such Asst. Public Prosecutor and creating a separate Prosecution Department and its Head directly responsible to Govt. for such Department's work.

Ans. The word "Arrest" when used in its ordinary sense means the restraint or the deprivation of one's personal liberty to go where he pleases. When used in the legal sense, an arrest consists of taking a person into custody under the authority empowered by law for the purpose of holding or detaining him to answer a criminal charge and preventing the commission of criminal offence. Section 46 of Criminal Procedure Code provides as to how arrest is to be made.

Section 46 says that in making an arrest the police officer or other person making the same shall actually touch and confine the body of the person to be arrested unless there be a submission to the custody by words or action.

In Rahimal v. State of U.P. 1992 Criminal Law Journal 3819, it was observed that Section 46 does not contemplate any formality before a person can be said to be taken in custody. Submission to custody by words or action is sufficient. But investigating officer should give full details as to in what manner the accused was arrested. Single sentence of I.O. regarding arrest without mentioning even the time and place is not sufficient to prove arrest.

ARREST BY PRIVATE PERSON Section 43 of Cr.P.C. provide that any private person may arrest or cause to be arrested any person:

(a) Who in his presence commits a non-bailable and cognizable offence.

(b) Who is a proclaimed offender.

Such private person after the arrest, without unnecessary delay shall make over or cause to be made over the person arrested to police officer or take him to nearest police station.

Sub-section (2) to Section 43 then provides that if the person so arrested appears to come under the provisions of Section 41 of Code, such police officer shall rearrest him. Section 43(3) says if the police officer has reason to believe that the person arrested has committed a non-cognizable offence provisions of Section 42 would apply if such arrested person refuses to give his name and address or gives a false name and address.

In Abdul Habib v. State 1974 Criminal Law Journal 248, it was held that a private person can not arrest any one on mere suspicion or information. The offence must be committed in his view or in his presence. Where therefore an individual seeing a person fleeing with the knife in his hand pursued by others, tries to arrest him his exercise of power of arrest cannot be brought under Section 43.

In Directorate of Enforcement v. Deepak Mahajan, AIR 1994 SC 1775, it was observed "The code gives power of arrest not only to a Police Officer and a Magistrate but also under certain circumstances or given situations to private persons. Further, when an accused person appears before a Magistrate or surrenders voluntarily, the Magistrate is empowered to take that accused person into custody and deal with him according to law. Needless to emphasize that the arrest of a person is a condition precedent for taking him into judicial custody thereof. To put it differently, the taking of the person into judicial custody is followed after the arrest of the person concerned by the Magistrate on appearance or surrender. In every arrest, there is custody but not vice-versa and that both the words `custody' and `arrest' are not synonymous terms."

Ans. ARREST WITHOUT WARRANT Section 41 of Criminal Procedure Code provides that any police officer may without an Order from Magistrate and without a warrant, arrest any person:

(a) who has been concerned in any cognizable offence or against whom a reasonable complaint has been made or credible information has been received or a reasonable suspicion exists of having been so concerned.

(b) who has in his possession without lawful excuse the burden of proving which excuse shall lie on such person, any implement of house breaking.

(c) who has been proclaimed as an offender either under this Code or by Order of the State Government; or

(d) in whose possession anything is found which may reasonably be suspected to be stolen property and who may reasonably be suspected of having committed an offence with reference to such thing; or

(e) who obstructs a police officer while in the execution of his duty, or who has escaped, or attempts to escape, from lawful custody; or

(f) who is reasonably suspected of being a deserter from any of the Armed Forces of the Union;

(g) who has been concerned in, or against whom a reasonable complaint has been made, or credible information has been received, or a reasonable suspicion exists, of his having been concerned in, any act committed at any place out of India which, if committed in India, would have been punishable as an offence, and for which he is, under any law relating to extradition, or otherwise, liable be apprehended or detained in custody in India; or

(h) who, being a released convict, commits a breach of any Rule, made under Sub-section (5) of Section 365 or

(i) for whose arrest any requisition, whether written or oral, has been received from another police officer, provided that the requisition specifies the person to be arrested and the offence or other cause for which the arrest is to be made and it appears therefrom that the person might lawfully be arrested without a warrant by the officer who issued the requisition [ Section 41(1)].

Any officer in charge of a police station may, in like manner, arrest or cause to be arrested any person, belonging to one or more of the categories of persons specified in Section 109 or Section 110 [ Section 41(2)]. When any person who, in the presence of a police officer, has committed or has been accused of committing a non-cognizable offence refuses, on demand of such officer, to give his name and residence or gives a name or residence which such officer has reason to believe to be false, he may be arrested by such officer in order that his name or residence may be ascertained. Section 42 of the Code.

Ans. Chapter v. of Code of Criminal Procedure contain provisions regarding arrest and rights of an arrested person.

Section 49 of Code says that the person arrested shall not be subjected to more restraint than necessary to prevent his escape.

Section 50 of Code further provides :

(1) Every Police Officer or other person arresting any person without warrant shall forthwith communicate to him full particulars of the offence for which he is arrested or other grounds for such arrest.

(2) Where a police officer arrests without warrant any person, other than a person, accused of a non-bailable offence, he shall inform the person arrested that he is entitled to be released on bail and that he may arrange for sureties on his behalf.

Section 51 then provide when on personal search of an arrested person contain articles are seized, a receipt showing the seizure of such articles shall be given to that person.

Section 53 of Code confers a right upon the investigating agency in respect of medical examination of arrested person for facilitating effective investigation. Then Section 54 of the Code provides: "When a person who is arrested whether on a charge or otherwise alleges, at the time when he is produced before Magistrate or at any time during the period of his detention in custody that the examination of his body will afford evidence which will disprove the commission by any other person of any offence against his body, the Magistrate shall, if requested by the arrested person so to do, direct the examination of the body of such person by a registered Medical Practitioner unless the Magistrate considers that the request is made for the purpose of vexation or delay or for defeating the ends of justice.

In Mukesh Kumar v. State (Delhi Admn.), 1990 Criminal Law Journal, 1923 it was observed that "In view of Section 54 Cr.P.C. whenever a person after being arrested is produced before Magistrate and alleges at any time during the period of his detention that examination of his body will afford evidence which will disprove his commission of offence, the Magistrate shall direct him to be examined by Medical Practitioner unless Magistrate considers the request as vexatious. Even in cases where accused does not make any prayer it is the duty of the court where such an accused is produced, particularly when he is unassisted by a lawyer to inform him of his right to be medically examined."

Then Section 56 of Code provides "A police officer making an arrest without warrant shall without unnecessary delay and subject to provisions of Code as to bail, take or send the person arrested before Magistrate having jurisdiction in the case or before the officer-in-charge of police station."

Section 57 also provides that "No police officer shall detain in custody a person arrested without warrant for a longer period than under all the circumstances of the case is reasonable and such period shall not in the absence of a special Order of a Magistrate under Section 167, exceed 24 hours exclusive of the time necessary for journey from the place of arrest to the Magistrate's court."

In Joginder Kumar v. State of U.P., AIR 1994 SC 1349, it was observed : No arrest can be made because it is lawful for the Police Officer to do so. The existence of the power to arrest is one thing. The justification for the exercise of it is quite another. The Police Officer must be able to justify the arrest apart from his power to do so. Arrest and detention in Police lock-up of a person can cause incalculable harm to the reputation and self esteem of a person. A person is not liable to arrest merely on the suspicion of complicity in an offence. There must be some reasonable justification in the opinion of the Officer effecting the arrest that such arrest is necessary and justified. Except in heinous offences, an arrest must be avoided if a Police Officer issues notice to person to attend the Station House and not to leave station without permission would do. Then, there is the right to have someone informed. That right of the arrested person, upon request, to have someone informed and to consult privately with a lawyer was recognised by Section 56(1) of the Police and Criminal Evidence Act, 1984 in England. These rights are inherent in Articles 21 and 22(1)of the Constitution and require to be recognised and scrupulously protected. For effective enforcement of these fundamental rights, the Supreme Court issued the following requirements :

(1) An arrested person being held in custody is entitled, if he so requests, to have one friend relative or other person who is known to him or likely to take an interest in his welfare told as far as is practicable that he has been arrested and where is being detained.

(1) The Police Officer shall inform the arrested person when he is brought to the Police Station of this right.

(3) An entry shall be required to be made in the Diary as to who was informed of the arrest. These protections from power must be held to flow from Articles 21 and 22(1) and enforced strictly.

It shall be the duty of the Magistrate, before whom the arrested person is produced, to satisfy himself that these requirements have been complied with.

Ans. Chapter VI of Code of Criminal Procedure deal with process to compel appearance namely Summons and Warrants. Sections 61 to 69 deal with Summons. Section 61 of Code says "Every summons issued by a court under this Code shall be in writing, in duplicate, signed by the presiding officer of such Court or by such other officer as the High Court may from time to time, by rule, direct and shall bear the seal of the Court.

So Summons is a document issued from the office of court of Justice calling upon the person to whom it is directed to attend before a Judge or officer of court. Summons is mild form of process whom it is addressed for (a) his appearance or (b) for producing document or thing. A summon may be sent to (i) Accused person (ii) a person to show cause against some order (iii) Person against whom proceeding for maintenance of wife or children neglected by him, is going on or (iv) Witness.

Distinction Between Summons and Warrant - A summons is always addressed to the person whose attendance is required, but warrant is not an order served on any person it is simply an order to Police to arrest a person against whom warrant is to be executed. Warrants can be bailable or non-bailable but there is no such distinction in case of Summons.

Service of Summons :- Section 62 of Code deals with the manner of service of summons. It says summons shall be served either by Police Officer or Officer of court issuing it, personally on person summoned by delivering or tendering to him one of duplicates of the summons, who shall sign a receipt on its back. Section 63 says service of summons on a corporation may be effected by serving it on the Secretary, Local Manager or other principal officer of Corporation either personally or by registered post.

When Person Summoned Can Not Be Found :- Section 64 of Code provides for service of summons on some adult male member of family if the person summoned can not be found despite the exercise of due diligence. But service on female members of the family is unwarranted.

Substituted Mode of Service :- Section 65 says -

If service cannot by the exercise of due diligence be effected as provided in Section 62, Section 63 or Section 64, the serving officer shall affix one of the duplicates of the summons to some conspicuous part of the house or homestead in which the person summoned ordinarily resides; and thereupon the Court, after making such inquiries as it thinks fit, may either declare that the summons has been duly served or order fresh service in such manner as it considers proper.

Service of Summons on Government Employees; Section 66 says services of summon on government employees can be effected either personally or through head of department in which such person is employed.

Service of Summons Outside Local Limits :- Section 67 of Code says-

When a Court desires that a summons issued by it shall be served at any place outside its local jurisdiction, it shall ordinarily send such summons in duplicate to a Magistrate within whose local jurisdiction the person summoned resides, or is, to be there served.

Then Section 68 says -

(1) When a summons issued by a Court is served outside its local jurisdiction, and in any case where the officer who has served a summons is not present at, the hearing of the case, an affidavit, purporting to be made before a Magistrate, that such summons has been served, and a duplicate of the summons purporting to be endorsed (in the manner provided by Section 62 or Section 64) by the person to whom it was delivered or tendered or with whom it was left, shall be admissible in evidence, and the statements made therein shall be deemed to be correct unless and until the contrary is proved.

(2) The affidavit mentioned in this section may be attached to the duplicate of the summons and returned to the Court.

Section 69 of Code provide regarding service of summons on witness by Post.

Ans. Section 70 of Code of Criminal Procedure says :-

"(1) Every warrant of arrest issued by a court under this code shall be in writing signed by the presiding officer of such court and shall bear the seal of the court.

(2) Every such warrant shall remain in force until it is cancelled by court which issued it or until it is executed."

So a warrant may be issued for the attendance of (1) an accused, (2) a person called upon to show cause against a Magistrate's order or (3) a witness subject to provisions of Section 87.

Section 71 of Code provides for issue of a bailable warrant but does not empower the court to order the physical delivery of arrested person to another. Then Section 72 says warrant of arrest shall ordinarily be directed to one or more police officers for its execution unless immediate execution is required. Section 73 says Chief Judicial Magistrate or Magistrate of first class, may direct a warrant to any person within his local jurisdiction for arrest of any escaped convict, proclaimed offender or accused or non-bailable offence, who shall acknowledge in writing the receipt thereof and will execute it. Similarly section 74 provide for warrant directed to police officer.

In C.B.I. v. Dawood Ibrahim Kasker, AIR 1997 SC 2494, it was observed that section 73 of the Code is of general application and that in course of investigation, a court can issue warrant in exercise of power thereunder to apprehend, inter-alia, a person who is accused of non-bailable offence and is evading arrest, the related question is as to whether such issuance of warrant can before his production before police in aid of investigation.....Since warrant is and can be issued for appearance be for the Court only and not before the police and since authorisation for detention in police custody is either to be given as matter of course not on mere asking of police, but only after exercise of judicial direction based on materials placed before him, so it cannot be said that warrant of arrest under section 73 could be issued by courts solely for production of accused before police in aid of investigation.

Execution of warrant of arrest outside the jurisdiction of the court issuing it. - When a warrant is to be executed outside the jurisdiction of the Court issuing it, it may instead of directing it to the police officer forward it by post or otherwise to any Executive Magistrate or District Superintendent of Police or Commissioner of Police within whose jurisdiction it is to be executed. The Executive Magistrate or District Superintendent of Police, or the Commissioner of Police on receiving it shall endorse his name thereon and cause it to be executed [Section 78]

The police-officer to whom the warrant has been directed shall go and get the endorsement of the Executive Magistrate or the concerned officer in charge of the police-station unless, delay in such endorsement may prevent execution, and then execute the warrant. After the arrest, the arrested person will be produced before the Magistrate in whose jurisdiction the arrest has been made.

Further the Court issuing a warrant under section 78(1) shall forward along with the warrant the substance of the information against the person to be arrested together with such documents, if any, as may be sufficient to enable the Court acting under section 81, Cr.P.C., to decide whether bail should not be granted to the person.

The person so arrested shall be taken before the Magistrate, District Superintendent of Police or Commissioner of Police within whose jurisdiction the arrest was made, unless -

(1) the Court issuing the warrant is within thirty kilometers of the place of arrest ;

(2) the Court issuing the warrant is nearer than they are ; or

(3) security is taken under section 71.

If the arrested person is taken to Magistrate, District Superintendent of Police or Commissioner of Police, they shall direct his removal in custody to the Court issuing the warrant, but if the offence is bailable, and the arrested person is ready to give bail, he shall be released on bail and the bond shall be forwarded to the Court which issued the warrant.

Ans. Section 82 of the Code of Criminal Procedure provides as to when and how proclamation can be issued for an absconding person. It lays down:

"82(1) If any Court has reason to believe (whether after taking evidence or not) that any person against whom a warrant has been issued by it has absconded or is concealing himself so that such warrant cannot be executed, such Court may publish a written proclamation requiring him to appear at a specified place and at a specified time not less than thirty days from the date of publishing such proclamation.

(2) The proclamation shall be published as follows:

(i) (a) it shall be publicly read in some conspicuous place of the town or village in which such person ordinarily resides;

(b) it shall be affixed to some conspicuous part of the house or homestead in which such person ordinarily resides or to some conspicuous places of such town or village;

(c) a copy thereof shall be affixed to some conspicuous part of the Court house;

(ii) the Court may also, if it thinks fit, direct a copy of the proclamation to be published in a daily newspaper circulating in the place in which such person ordinarily resides

(3) A statement in writing by the Court issuing the proclamation to the effect that the proclamation was duly published on a specified day, in the manner specified in clause (i) of Sub-section (2), shall be conclusive evidence that the requirements of this Section have been complied with, and that the proclamation was published on such day."

So Section 82 of the code provides that if any court had reason to believe that any person against whom a warrant had been issued by it, had absconded or was concealing himself so that such warrant could not be executed, such court may publish a written proclamation requiring him to appear at specified place and at specified time not less than 30 days from date of publishing such proclamation.

In Devender Singh v. State of U.P. 1993(2) Crimes 728 Allahabad High Court has observed:

"The words" has absconded or is concealing himself so that such warrant can not be executed" in Section 82 of Code are significant. Every person who is not immediately available can not be characterised as an absconder. The Court has to record its satisfaction that the accused has absconded or is concealing in order to avoid execution of the warrant. The provisions of Section 82 requires that the court must in the first instance, issue a warrant and it must put down its reason for believing that the accused is absconding or concealing himself.

Ans. Attachment of Property of Person Absconding : (1) According to Section 83 of Code of Criminal Procedure, the court issuing proclamation under Section 82 may for the reasons recorded in writing at any time after the issue of proclamation, order the attachment of any property moveable or immovable or both belonging to proclaimed person:

Provided that where at the time of the issue of the proclamation, the court is satisfied by affidavit or otherwise, that person in relation to whom the proclamation is to be issued,

(a) is about to dispose of the whole or any part of his property; or

(b) is about to remove the whole or any part of his property from the local jurisdiction of the Court,

it may Order the attachment simultaneously with the issue of the proclamation.

(2) Such order shall authorise the attachment of any property belonging to such person within the district in which it is made, and it shall authorise the attachment of any property belonging to such person within the district when endorsed by the Magistrate or Chief Metropolitan Magistrate within whose district such property is situated.

(3) If property ordered to be attached is a debt or other movable property the attachment under this Section shall be made

(a) by seizure; or

(b) by appointment of receiver; or

(c) by an order in writing prohibiting the delivery of such property to the proclaimed person or to any one on his behalf; or

(d) by all or any of the two of such methods, as the Court thinks fit.

(4) If the property ordered to be attached is immovable property, the attachment under this Section shall, in case of land, paying revenue to the State Government, be made through Collector of District in which the land is situate, and in all other cases :

(e) by taking possession; or

(f) by the appointment of receiver; or

(g) by an order in writing prohibiting the payment of rent or delivery of property to the proclaimed person or to anyone on his behalf; or

(5) If the property ordered to be attached consists of livestock or is of a perishable nature the Court may, if it thinks it expedient, order immediate sale thereof, and in such case the proceeds of sale shall abide the Order of the Court.

(6) The powers, duties and liabilities of a receiver appointed under this Section shall be the same as those of a receiver appointed under the Code of Civil Procedure, 1908.

Object of Section 83 : The object of Section 83 is to penalize a person who seeks to avoid his arrest under warrant and against whom a proclamation is issued under Section 82, for disobedience of the proclamation, he incurs liability to be punished under Section 174 of the Indian Penal Code. The provision is devised to put additional pressure upon the absconder by depriving him of his property with a view to compel him to obedience.

Ans. Section 84 of Cr.P.C. provides Claims and objections to attachment. -

"(1) If any claim is preferred to, or objection made to the attachment of, any property attached under section 83, within six months from the date of such attachment, by any person other than the proclaimed person, on the ground that the claimant or objector has an interest in such property, and that such interest is not liable to attachment under section 83, the claim or objection shall be inquired into, and may be allowed or disallowed in whole or in part:

Provided that any claim preferred or objection made within the period allowed by this sub-section may, in the event of the death of the claimant or objector, be continued by his legal representative.

(2) Claims or objections under sub-section (1) may be preferred or made in the Court by which the order of attachment is issued, or, if the claim or objection is in respect of property attached under an order endorsed under sub-section (2) of section 83, in the Court of the chief Judicial Magistrate of the district in which the attachment is made.

(3) Every such claim or objection shall be inquired into by the Court in which it is preferred or made :

Provided that, if it is preferred or made in the Court of a Chief Judicial Magistrate, he may make it over for disposal to any Magistrate subordinate to him.

(4) Any person whose claim or objection has been disallowed in whole or in part by an order under sub-section (1) may, within a period of one year from the date of such order, institute a suit to establish the right which he claims in respect of the property in dispute; but subject to the result of such suit, if any, the order shall be conclusive."

And Section 85 of code says :-

"(1) If the proclaimed person appears within the time specified in the proclamation, the Court shall make an order releasing the property from the attachment.

(2) If the proclaimed person does not appear within the time specified in the proclamation, the property under the attachment shall be at the disposal of the State Government; but it shall not be sold until the expiration of six months from the date of the attachment and until any claim preferred or objection made under section 84 has been disposed of under that section, unless it is subject to speedy and natural decay, or the Court considers that the sale would be for the benefit of the owner; in either of which cases the Court may cause it to be sold whenever it thinks fit.

(3) If, within two years from the date of the attachment, any person whose property is or has been at the disposal of the State Government, under sub-section (2), appears voluntarily or is apprehended and brought before the Court by whose order the property was attached, or the Court to which such Court is subordinate, and proves to the satisfaction of such Court that he did not abscond or conceal himself for the purpose of avoiding execution of the warrant, and that he had not such notice of the proclamation as to enable him to attend within the time specified therein, such property, or, if the same has been sold, the net proceeds of the sale, or, if part only thereof has been sold, the net proceeds of the sale and the residue of the property, shall, after satisfying therefrom all costs incurred in consequence of the attachment, be delivered to him."

Ans. (a) Section 87 of the Code of Criminal Procedure empowers a Court to issue warrant in lieu of, or in addition to, summons. It provides: `A court may, in any case in which it is empowered by this Code to issue a summons for the appearance of any person, issue, after recording its reasons in writing, a warrant for his arrest

(a) if, either before the issue of such summons, or after the issue of the same but before the time fixed for his appearance, the Court sees reason to believe that he has absconded or will not obey the summons; or

(b) if at such time he fails to appear and the summons is proved to have been duly served in time to admit of his appearing in accordance therewith and no reasonable excuse is offered for such failure.

(b) Section 88 of the Code of Criminal Procedure empowers the Court to take bond for appearance. It lays down that when any person for whose appearance or arrest the officer presiding in any Court is empowered to issue a summons or warrant, is present in such Court, such officer may require such person to execute a bond, with or without sureties, for his appearance in such Court, or any other Court to which the case may be transferred for trial.

(c) Section 89 of the Code of Criminal Procedure enacts that when any person who is bound by any bond taken under this Code to appear before a Court, does not appear, the officer presiding in such Court may issue a warrant directing that such person be arrested and produced before him. Section 89 has reference to the case of a person who is bound by a bond to appear in the court. It provides for a warrant only in case the person does not appear at the time when he is bound by the bond to appear; but it does not apply to a case where prior to the time for appearance, arrest by warrant is sought to be effected. Such a case falls under Section 87. If the accused released on bail, by his repeated absence on the dates fixed for hearing, hinders the case being proceeded with, it is open to the trial magistrate to apply this Section . When the magistrate cancels the bail bond of the person accused of a bailable offence it is within his right to cause his rearrest.

Ans. Summons to produce document or other thing Section 91 says that - Where any court, or any officer-in-charge of a police station considers that production of any document or other thing is necessary or desirable for purposes of any investigation, inquiry or trial or other proceeding under the Criminal Procedure Code by or before such court or officer, such court may issue summons or a written order to the persons in whose possession or power such document or thing is believed to be, requiring him to attend and produce it, or to produce it at the time and place stated in the summons or the order.

Section 91, on its true construction, does not apply to an accused person under trial. If it were the intention of the Legislature to make Section 91 applicable to an accused person, it could have so stated in specific words. If he does not produce it, a search warrant may be issued under Section 92 of the Code.

In Om Parkash Sharma v. C.B.I., Delhi, AIR 2000 SC 2335, it was observed that while considering the application under section 91 Cr. P.C. for summoning and production of documents, the question before the Trial Court would be to address itself to find whether there is sufficient ground for proceeding to next stage against the accused if the accused could produce any reliable material even at that stage which might totally affect even the very sustainability of the case, a refusal to took into materials so produced may result in injustice......It is trite law that standard of proof normally adhered to, at the final stage is not to be insisted upon at the stage is not to be confined to find out a prima facie case and to decide whether it is necessary to proceed to next stage of framing charges and making the accused to stand trial.

Section 92 lays down that if such document or thing is in the custody of postal or telegraph authorities in the opinion of the District Magistrate, Chief Judicial Magistrate, Court of Session or High Court is wanted for the purposes of any investigation, inquiry or trial or other proceeding under this Code such Magistrate or court may require the postal or telegraph authority as the case may be to deliver the document, parcel or thing or such person as the Magistrate or Court directs.

Ans. Section 106 of Code of Criminal Procedure provides for security being taken on conviction for certain offences. Section 106 reads as under :-

(1) When a Court of Session or Court of a Magistrate of the first class convicts a person of any of the offences specified in Sub-section (2) or of abetting any such offence and is of opinion that it is necessary to take security from such person for keeping the peace, the Court may, at the time of passing sentence on such person, order him to execute a bond, with or without sureties, for keeping the peace for such period, not exceeding three years, as it thinks fit.

(2) The offences referred to in Sub-section (1) are -

(a) any offence punishable under Chapter VII of the Indian Penal Code (45 of 1860), other than an offence punishable under Section 153-A or Section 153-B or Section 154 thereof;

(b) any offence which consists of, or includes, assault or using criminal force or committing mischief;

(c) any offence of criminal intimidation;

(d) any other offence which caused, or was intended or known to be likely to cause, a breach of the peace.

(3) If the conviction is set aside on appeal or otherwise, the bond so executed shall become void.

(4) An order under this section may also be made by an Appellate Court or by a Court when exercising its powers of revision.

The object of an order under section 106 is not to punish but to prevent the commission of offence in future. In Madhu Limay v. S.D.M. Monghys, 1971 Cri.L.J. 1720 (SC). It was observed that in order that Section 106 may apply it is necessary -

(i) that there must be a conviction,

(ii) that the conviction is for one of offences specified in Sub- section (2)

(iii); that such conviction is by one of the courts mentioned in Sub- section (1)

(iv); that reason of conviction of a person his past conducts leads to an apprehension for the future."

Then Section 107 of Code deals with security for keeping the peace in other cases. According to Section 107 when a court is informed that the person is likely to (1) Commit a breach of peace, or (2) disturb the public tranquility, the Magistrate may require such person to execute a bond with or without sureties for keeping the peace for a period not exceeding one year.

For initiating proceedings under section 107, it is necessary that -

(a) Magistrate should be satisfied that there are sufficient reasons for proceedings &

(b) the Magistrate should record reasons for his satisfaction

(c) issue notice to the person against whom he wishes to proceed to show cause why proceedings under this section be not taken against him.

For good behaviour. - Sections 108, 109 and 110 prescribe the circumstances under which persons are required to execute a bond for good behaviour :

(1) Section 108 provide that when persons disseminate seditious matter promoting enmity between classes or concerning a Judge acting or purporting to act in the discharge of his official duties amounting to criminal intimidation or defamation.

(2) Under Section 109 when a vagrant or suspect person takes precautions to conceal his presence with a view to committing any offence, or cannot give a satisfactory account of himself.

(3) Under Section 10, if the person is a habitual offender -- i.e.,

(I) the person is by habit a robber, house-breaker, thief, forger, a receiver of stolen property;

(II) habitually protects or harbours thieves ;

(III) habitually commits kidnaping, abduction, extortion, cheating or mischief,

(IV) habitually commits or attempts to commit or abets the commission of --

(i) any offence under one or more of the Drugs and Cosmetics Act, Foreign Exchange Regulation Act, Prevention of Food and Adulteration Act, Essential Commodities Act, Untouchability (Offences) Act, the Customs Act and Employees Provident Funds Act,

(ii) any offence punishable under any other law providing for the prevention of hoarding or profiteering or of adulteration of food or drugs or of corruption, or

(iii) is so desperate hazardous as to render his being at large without security hazardous to the community he may be required to execute a bond for good behaviour.

Ans. Section 47(1) of Code of Criminal Procedure provide regarding search of place where, person acting under the warrant of arrest or police officer has reason to believe that person to be arrested has entered and provide that any person residing or incharge of such place shall on demand allow free ingress and afford all reasonable facilities for search. Section 42(2) says if the ingress to such place cannot be so obtained, it shall be lawful for person acting under a warrant or in any case where warrant can be issued but cannot be obtained without affording opportunity to the person to be arrested to escape to enter such place and search therein and for entrance to break open any other or inner door or window of the house or place.

Section 51 of Code deals with the search of an arrested person. Section 51 requires that police officer making arrest may search person arrested and place in safe custody all the articles other than necessary wearing apparel found upon him and receipt showing the article taken in possession by the police officer shall be given to such person. Though it is desirable to seal the recovered article at the spot in order to avoid any dispute about its identity but it is not obligatory in a case when there is no question about identity of Article recovered. Sub-section (2) provides that whenever it is necessary to cause a female to be searched, the search shall be made by another female with strict regard to decency.

Section 93 of Criminal Procedure Code provides that "Search Warrant" can be issued if the court has reason to believe that:

(a) A person who inspite of summons or requisition under Sections 91 and 92 of Code, to produce a document, will not or would not produce it or

(b) Where such document or thing is not known to the Court to be in possession of any person.

(c) Where general inspection or search is necessary.

Section 94 of Code then provides that when District Magistrate or Sub-Divisional Magistrate or Magistrate of First Class has any information or reason to believe that any place is used for deposit or sale of stolen property or objectionable articles to which Sub-section (2) of Section 94 applies, he may by warrant authorise any police officer above the rank of constable, to enter into such place and to search the place and to take into possession of any such stolen property or any objectionable article, found therein and to convey such property or article before Magistrate.

Section 97 of Cr.P.C. also empowers any District Magistrate, Sub-Divisional Magistrate or Magistrate of First Class to issue search warrant if Magistrate has reason to believe that any person is wrongfully and unlawfully confined in any place.

In V. S. Kuttar Pillai v. Ramakrishna and other AIR 1980 SC 185, it was held that search and seizer pursuant to warrant under Section 93 obtained during investigation is nothing but an integral step in an investigation. Search and seized pursuant to search warrant will not have even the remotest tendency to compel the accused to incriminate himself.

Of course issuance of search warrant is a serious matter and it would be advisable not to dispose of an application for search warrant in a mechanical way. Issuance of search warrant being in the discretion of Magistrate it would be reasonable to expect of the Magistrate to give reasons which swayed his discretion in favour of issuing search warrant.

Section 165 of Code is another important provision which provides that a police officer making an investigation has reason to believe that anything necessary for the purpose of an investigation may be found in any place within the limits of his police station and such thing in his opinion cannot otherwise be obtained without undue delay, such police officer after recording in writing, his grounds of belief, search or cause the search to be made for such thing and search shall be made in accordance with general provisions as to search contained under Section 100 of Code.

Ans. Chapter IX of Code of Criminal Procedure containing Sections 125 to 128 deal with order of Maintenance of Wives, Children and parents. Section 125 of Code gives effect to natural and fundamental duty of a man to maintain his wife, children and parents, so long as they are unable to maintain. Its provisions apply to all and are enforceable, whatever may be personal law by which the persons concerned are governed. The object of these proceeding is to prevent vagrancy in the society, by compelling those persons who could maintain those who are unable to maintain themselves.

Vide Amendment Act No. 50 of 2001 a landmark change has been made in section 125 Cr.PC. i.e. in place of maximum amount of maintenance of Rs. 500/- no maximum limit for maintenance amount has been fixed, moreover express provision for interim maintenance has also been incorporated in the section.

Section 125 of Code provides that any person having sufficient means if neglects or refuses to maintain

(a) His wife unable to maintain herself.

(b) His legitimate or illegitimate minor child whether married or not, unable to maintain itself.

(c) His legitimate or illegitimate Major child (Not being married daughter) who by reason of any physical or mental abnormality or injury unable to maintain itself.

(d) His father or mother unable to maintain himself or herself.

Magistrate upon proof of such neglect or refusal, order such person to make any amount of monthly maintenance allowance for each of the above stated persons.

As per the second proviso to section 125 a Magistrate may during pendency of the proceedings regarding monthly allowance for maintenance order for the interim maintenance of wife, child, father or mother. Provided that application for interim maintenance will be disposed of within 60 days from the date of service of notice to the other party.

In 1999 Criminal Law Journal 2919, it was held that though proceedings under section 125 are wholly governed by Criminal Procedure Code and application for maintenance is entertained and disposed of by a Magistrate, proceedings are in reality of Civil nature.

So very basis of proceedings under Section 125 of code are two fold. Firstly the person from whom Maintenance is claimed must have sufficient means and he neglects or refuses to maintain. Secondly person who claims maintenance must be unable to maintain himself or herself.

In Narain Sahu v. Sushama 1992 Criminal Law Journal 2912 it was held that no order for maintenance can be passed under Section 125 unless neglect or refusal to maintain is proved. Neglect or refusal to maintain can even be inferred from conduct.

Sub-section (3) of Section 125 of Code then provides that if any person against whom an order has been made, has failed to comply with the order, Magistrate may issue warrant for levying the amount of maintenance in the same manner as provided for levying fines and may sentence the person in default to imprisonment for a term of one month for every breach of order.

In Priyal v. Dr.Pradeep Kumar Kamboj, 2000(2) Recent Criminal Reports 217 Minor child was claiming maintenance under Section 125 of code from father who was living in U.S.A. The Punjab and Haryana High Court directed that Magistrate to issue warrant for recovery of amount of maintenance to concerned court in U.S.A. through Ambassador of India in U.S.A. and if father fails to send amount of maintenance then, Magistrate will proceed according to law in this regard.

Section 125(4) of code provides that in following circumstances, wife is not entitled to receive maintenance from her husband

(i) If wife is living in adultery

(ii) If wife without any sufficient reasons refuses to live with her husband

(iii) If husband and wife are living separately by Mutual Consent. Second Proviso to Section 125(3) also provides that if husband offers to maintain his wife on the condition of her living with him and she refuses to live with him. Magistrate may after considering the offer, make an order under this Section if he is satisfied that there is just ground for so doing.

In Rohtas Singh v. Smt. Ramenderi AIR 2000 SC 952 Supreme Court held that `For the purpose of Maintenance under Section 125 of Cr.P.C., as provided in Explanation (b) to Sub-section (i) of Section 125 `Wife' includes woman who has been divorced or obtained divorce from her husband. So a woman who has been divorced on account of a decree passed under Hindu Marriage Act, continues to enjoy status of `Wife' for limited purpose of Maintenance. Therefore, wife against whom decree for Divorce has been passed on account of her deserting her husband can claim maintenance allowance under Section 125.

Ans. No wife shall be entitled to receive an allowance as maintenance from her husband under Section 125, Cr.P.C., if she is living in adultery, or if without any sufficient reason, she refuses to live with her husband, or if they are living separately by mutual consent.

She is disentitled to maintenance when she is living in adultery. Phrase `living in adultery' is of special importance. It means that the wife is living in a continuous adulterous conduct as different from a single act of adultery.

Passing of a decree of judicial separation against the wife disentitles her to claim maintenance because she has no reasonable ground for not living with her husband.

The Magistrate shall cancel the order of maintenance on proof that the wife in whose favour an order has been made under Section 125, Criminal Procedure Code, is living in adultery, or without sufficient reason she refuses to live with her husband or that they are living separated by mutual consent.

Ans. Section 127 of Criminal Procedure Code deals with the alteration in the maintenance allowance. After the Amendment Act No. 50 of 2001 as maximum limit of maintenance has not been fixed now, Amendment has been made in section 127 of Code also. Section 127 reads as under :

"(1) On proof of a change in the circumstances of any person, receiving under section under section 125 a monthly allowance, for the maintenance or interim maintenance, or ordered under the same section to pay a monthly allowance for the maintenance, or interim maintenance to his wife, child, father or mother, as the case may be, the Magistrate may makes such alteration, as he thinks fit, in the allowance for the maintenance or the interim maintenance as the case may be.

Provided that if he increases the allowance, the monthly rate of five hundred in the whole shall not be exceeded.

(2) Where it appears Magistrate that in consequence of any decision of a competent civil court, any order made under section 125 should be cancelled or varied, he shall cancel the order or, as the case may be, vary the same accordingly.

(3) Where any order has been made under section 125 in favour of a woman who has been divorced by, or has obtained a divorce from her husband, the Magistrate shall, if he is satisfied that -

(a) the woman has, after the date of such divorce, re-married, cancel such order as from the date of her re-marriage;

(b) the woman has been divorced by her husband and that she has received, whether before or after the date of said order, the whole of the sum which, under any customary or personal law applicable to the parties, was payable on such divorce, cancel such order -

(i) in the case where such sum was paid before such order, from the date on which such order was made;

(ii) in any other case, from the date of expiry of the period, if any, for which maintenance has been actually paid by the husband to the woman;

(c) the woman has obtained a divorce from her husband and that she had voluntarily surrendered her rights of maintenance or interim maintenance as the case may be after her divorce, cancel the order from the date thereof.

(4) At the time of making any decree for the recovery of any maintenance or dowry by any person, to whom a monthly allowance for the maintenance and interim maintenance or any of them has been ordered to be paid under section 125, the Civil Court shall take into account the sum which has been paid to, or recovered by such person as monthly allowance for the maintenance and interim maintenance or any of them, as the case may be, in pursuance of the said order.

Ans. Sections 133 to 145 of the Code of Criminal Procedure, 1973 deal with the powers and procedure for the removal of unlawful obstruction or nuisance from a public place, way, river or channel which is or may be lawfully used by the public. Section 144 empowers certain executive authorities to issue orders in urgent cases of nuisance and apprehended danger. Section 144(1) provides: "In cases where, in the opinion of a District Magistrate, a Sub-Divisional Magistrate or any other Executive Magistrate specially empowered by the State Government in this behalf, there is sufficient ground for proceeding under this Section and immediate prevention or speedy remedy is desirable, such Magistrate may, by a written order stating the material facts of the case and served in the manner provided by Section 134 direct any person to abstain from a certain act or to take certain order with respect to certain property in his possession or under his management, if such Magistrate considers that such direction is likely to prevent, or tends to prevent, obstruction, annoyance or injury to any person lawfully employed, or danger to human life, health or safety, or a disturbance of the public tranquility, or a riot, or an affray".

In Gulam Abbas v. State of U.P., AIR 1981 SC 2198, the Supreme Court observed: "The entire basis of action under Section 144 is provided by the urgency of the situation and the power thereunder is intended to be availed of for preventing disorders, obstructions and annoyances with a view to secure the public weal by maintaining public peace and tranquility. Preservation of the public peace and tranquility is the primary function of the Government and the power under Section 144 is conferred on the executive magistracy enabling it to perform that function effectively during emergents.

It is further well settled that the Section does not confer any power on the Executive Magistrate to adjudicate or decide disputes of civil nature or questions of title to properties or entitlements to rights but at the same time in cases where such disputes or titles or entitlements to rights have already been adjudicated and have become the subject matter of judicial pronouncements and decrees of civil courts of competent jurisdiction then in the exercise of his power under Section 144 he must have due regard to such established rights subject of course to the paramount consideration of maintenance of public peace and tranquility.

Ans. Dispersal of assembly by use of civil force. Section 129 of Cri. P.C. provides :-

"(1) Any Executive Magistrate or officer-in-charge of a police station or, in the absence of such officer-in-charge, any police officer, not below the rank of a sub-inspector, may command any lawful assembly, or any assembly of five or more persons likely to cause a disturbance of the public peace, to disperse; and it shall thereupon be the duty of the members of such assembly to disperse accordingly.

(2) If, upon being so commanded, any such assembly does not disperse, or if, without being so commanded, it conducts itself in such a manner as to show a determination not to disperse, any Executive magistrate or police officer referred to in sub-section (1), may proceed to disperse such assembly by force, and may require the assistance of any male person, not being an officer or member of the armed forces and acting as such, for the purpose of dispersing such assembly, and, if necessary, arresting and confining the persons who form part of it, in order to disperse such assembly or that they may be punished according to law."

Section 130 of code says :-

"(1) If any such assembly cannot be otherwise dispersed, and if it is necessary for the public security that it should be dispersed, the Executive Magistrate of the highest rank who is present may cause it to be dispersed by the armed forces.

(2) Such Magistrate may require any officer in command of any group of person belonging to the armed forces to disperse the assembly with the help of the armed forces under his command, and to arrest and confine such persons forming part of it as the Magistrate may direct, or as it may be necessary to arrest and confine in order to disperse the assembly or to have them punished according to law.

(3) Every such officer of the armed forces shall obey such requisition in such manner as he thinks fit, but in so doing he shall use as little force, and do as little injury to person and property, as may be consistent with dispersing the assembly and arresting and detaining such persons."

Ans. Section 133 of Code of Criminal Procedure says :-

"(1) Whenever a District Magistrate or Sub-divisional Magistrate or any other Executive Magistrate specially empowered in this behalf by the State Government, on receiving the report of a police-officer or other information and on taking such evidence (if any) as he thinks fit, considers -

(a) that any unlawful obstruction or nuisance should be removed from any public place or from any way, river or channel which is or may be lawfully used by the public; or

(b) that the conduct of any trade or occupation, or the keeping of any goods or merchandise, is injurious to the health or physical comfort of the community, and that in consequence such trade or occupation should be prohibited or regulated or such goods or merchandise should be removed or the keeping thereof regulated; or

(c) that the construction of any building, or, the disposal of any substance, as is likely to occasion conflagration to explosion, should be prevented or stopped; or

(d) that any building, tent or structure, or any tree is in such a condition that it is likely to fall and thereby cause injury to persons living or carrying on business in the neighbourhood or passing by, and that in consequence the removal, repair or support of such building, tent or structure, or the removal or support of such tree, is necessary; or

(e) that any tank, well or excavation adjacent to any such way or public place should be fenced in such manner as to prevent danger arising to the public; or

(f) that any dangerous animal should be destroyed, confined or otherwise dispose of,

such Magistrate may make a conditional order requiring the person causing such obstruction or nuisance, or carrying on such trade or occupation, or keeping any such goods or merchandise, or owning or possessing or controlling such building, tent, structure, substance, tank, well or excavation, or owning or possessing such animal or tree, within a time to be fixed in the order -

(i) to remove such obstruction or nuisance; or

(ii) to desist from carrying on, or to remove or regulate in such manner as may be directed, such trade or occupation, or to remove such goods or merchandise, or to regulate the keeping thereof in such manner as may be directed; or

(iii) to prevent or stop the construction of such building, or to alter the disposal of such substance; or

(iv) to remove, repair or support such building, tent or structure, or to remove or support such trees; or

(v) to fence such tank, well or excavation; or

(vi) to destroy, confine or dispose of such dangerous animal in the manner provided in the said order,

or, if he objects so to do, to appear before himself or some other Executive Magistrate subordinate to him at a time and place to be fixed by the order and show cause, in the manner hereinafter provided, why the order should not be made absolute.

(2) No order duly made by a Magistrate under this section shall be called in question in any Civil Court."

The whole object of Section 133 is that the public should not suffer and that such dangers or obstructions caused by the members of the public should be removed at the earliest possible moment. The proceedings under Section 133 is not to be taken in a case where there has been a long user. It is not intended that the proceeding under that section should be substituted for civil suit in a Civil Court.

Section 133 empowers a District Magistrate, or a Sub-divisional Magistrate, or an Executive Magistrate to take action only where there has been an invasion of public right. Proceedings under the section are not intended to protect the public as a whole against inconvenience. Before action can be taken under section 133, the obstruction or nuisance must be proved to exist on some way, river, channel which may lawfully be used by the public or on some public place. If the obstruction or nuisance is on some private property action under this section cannot be taken.

Ans. Sections 145 to 148 of Criminal Procedure Code deal with procedure to be adopted in cases of dispute as to immovable property. Section 145(1) provides that whenever Executive Magistrate is satisfied either upon police report or other information that dispute is likely to cause breach of peace concerning any land etc. within his local jurisdiction, he shall make an order containing grounds of being so satisfied and requiring parties in dispute to attend his court either in person or by pleader on specified date and to put their written statements as to their respective claim concerning actual possession of property in dispute. Section 145(3) says copy of such order shall be served in the same manner as provided for service of summons in Cr.P.C. or by affixing copy of order at some conspicuous place at or near property in dispute.

Section 145(4) then prescribe the procedure to be adopted by Magistrate in an enquiry. However Magistrate making enquiry under this Section can not decide the question of title. Enquiry of Magistrate shall be confined to decide whether any and which party was in possession of subject in dispute on date of passing preliminary order under section 145(1).

Provided that if it appears to Magistrate that any party has been wrongfully and forcibly dispossessed within 2 months before date of receiving police report or other information or date of passing preliminary order, he may treat party so dispossessed to be in possession on the date of passing preliminary order under Section 145(1). In 1999 Criminal Law Journal 98 Punjab and Haryana High Court has held that when there is civil suit pending over the disputed land and civil court has ordered the status quo to be maintained by parties, the Executive Magistrate is incompetent to decide and possession of such property under Section 145 Cr.P.C.

In Amresh Tiwari v. Lalta Prasad Dubey, AIR 2000 SC 1504, Supreme Court observed that it cannot be said that in every case where a civil suit is filed, Section 145 proceedings would never lie. It is only in cases where civil suit is for possession or for declaration of title in respect of same property and where relief regarding protection of property concerned can be applied for and granted by Civil Court only, that proceedings under section 145 should be allowed to continue.

Section 145(6) of Code then provide that Magistrate shall decide that one of the parties was or should be deemed to be in possession under the provision to Sub-section (4) and shall issue an order declaring such party is entitled to possession until evicted therefrom in due course of law and forbidding any disturbance of such possession until such eviction. Magistrate can issue order for restoration of possession of party who was forcibly and wrongfully dispossessed.

Section 145(7) provide that if during proceeding under this Section if any party dies then legal representative of such deceased shall be impleaded as party. Sub-section (8) provide for passing necessary order in respect of crop etc. in property in dispute.

Section 146 of the Code further provides that if the Magistrate at any time after making the preliminary order considers the case to be one of emergency, or if he decides that none of the parties was then in such possession, or if he is unable to satisfy himself as to which of them was then in possession of the subject of dispute, he may attach the subject of dispute until a competent court had determined the rights of the parties thereto with regard to the person entitled to the possession thereof. Pending such determination, the Magistrate may appoint a receiver to look after the attached property. The object of attachment is to keep the property in custodian legis so as to prevent the contesting parties from creating the breach of peace in their attempts to obtain the actual possession of property.

In Dharampal v. Ramshri, AIR 1993 SC 1361, it was observed that under section 146, the Magistrate is given power to attach the subject of dispute "until the competent Court has determined the rights of the parties thereto with regard to the person entitled to the possession thereof." The determination by a competent Court of the rights of the parties spoken of there has not necessarily to be a final determination. The determination may be even tentative at the interim stage when the competent Court passes an order of interim injunction or appoints a receiver in respect of the subject-matter of the dispute pending the final decision in the suit. The moment the competent Court does so, even at the interim stage, the order of attachment passed by the Magistrate has to come to an end. Otherwise, there will be inconsistency between the order passed by the civil court and the order of attachment passed by the Magistrate.

In R.H. Bhutani v. Mani J. Desai AIR 1968 SC 1444, it was observed that object of Sections 145 and 146 is to bring to an end by a summary process disputes relating to property which are essentially of a civil nature with a view to prevent breach of peace. Section is to provide speedy remedy by bringing the parties before the court and ascertaining who of them was in actual possession and to maintain status quo until their rights are determined by competent court. Enquiry under this Section is limited to question as to who was in actual possession on the date of preliminary order irrespective of the rights of parties.

Ans. Police to prevent cognizable offence. - Under Section 149 - Every police officer may interpose for purpose of preventing and shall, to the best of his ability, prevent the commission of any cognizable offence.

Information of design to commit such offence. - Section 150 makes it obligatory of every police officer receiving such information of a design to commit any cognizable offence to communicate such information to the police officer to whom he is subordinate, and to any other officer whose duty is to prevent or to take cognizance of the commission of any such offence.

Arrest to Prevent such offence. - Section 151 empowers police officer knowing of a design to commit any cognizable offence to arrest, without orders from Magistrate and without a warrant, the person so designing, if it appears to such officer that the commission of the offence cannot be otherwise, prevented.

No person arrested under sub-section (1) shall be detained in his custody for a period exceeding twenty-four hours from the time of his arrest unless his further detention is required or authorised under any other provisions of this Code or of any other law for the time being in force.

Prevention of injury to public property. - According to Section 152, a police officer may of his own authority interpose to prevent any injury attempted to be committed in his view to any public property, movable or immovable, or the removal or injury of any public landmark or body or other landmark used for navigation.

Inspection of weights and measures. - Section 153 empowers police to inspect weights and measures. It lays down :-

(1) Any officer incharge of a police station may, without a warrant, enter any place within the limits of such station for the purpose of inspecting or searching for any weights or measures or instrument for weighing, used or kept therein, whenever he has reason to believe that there are in such place any weights, measures or instrument for weighing which are false.

(2) If he finds in such place any weights, measures or instruments for weighing which are false, he may seize the same and shall forthwith give information of such seizure to a Magistrate having jurisdiction.

Ans. (i) First Information Report (F.I.R.) : First Information Report, in simple words means the information given at first point of time, regarding the commission of crime. The principal object of the First Information Report, from the informant's point of view is to set the criminal law in motion and from the point of view of Investigating Authorities is to obtain information about any criminal activity so as to be able take suitable step of collecting evidence and trace and bring to book the culprits

Section 154 of Criminal Procedure Code provide for recording First Information Report. Section 154(1) says "Every information relating to commission of cognizable offence if given orally to an officer in charge of police station, shall be reduced to writing by him or under his direction and be read over to the informant and every such information whether given in writing or reduced to writing as aforesaid shall be signed by person giving it and the substance thereof shall be entered in a book kept by such officer in such form as State Government may prescribe in this behalf."

Sub-section (2) to Section 154 says that copy of such information report shall be given free of cost to the informant.

In State of Haryana v. Bhajan Lal 1992 Criminal Law Journal 527, it was observed that if any information disclosing the cognizable offence is laid before an officer in charge of police station satisfying the requirements of Section 154(1), he has no option except to enter substance thereof in the prescribed form, that is to say to register a case on the basis of such information.

Sub-section (3) to Section 154 of Code then provides remedy in case of refusal on the part of officer-in-charge of police station to record the information. The aggrieved person may send the substance of such information in writing and by post to the Superintendent of Police concerned.

Evidentiary Value of F.I.R. In Ram Kumar Pandey v. State of M.P. AIR 1975 SC 1206 Supreme Court observed that "An F.I.R. is not a substantive piece of evidence and can only be used to corroborate the statement of the maker under Section 157 of Evidence Act or to contradict it under Section 145 of said Act. It can only be used for corroboration or contradiction purposes that too when FIR was lodged by person having direct knowledge about the occurrence.

In State of M.P. v. Surhhan, AIR 1996 SC 3345, it was observed FIR cannot be used as a substantive evidence or for corrohrating statement of third party. It cannot be used either to corroborate or for contradiction of its maker.

Ans. Section 155 of Code of Criminal Procedure deal with information as to non-cognizable cases and the investigation thereof. A "Non-cognizable offence" means an offence for which and "non-cognizable case" means a case in which, a police officer has no authority to arrest without warrants [Section 2(i)]

Section 155 of Code reads as under :-

(1) When information is given to an officer in charge of a police station of the commission within the limits of such station of a non-cognizable offence, he shall enter or cause to be entered the substance of the information in a book to be kept by such officer in such form as the State Government may prescribe in this behalf, and refer the informant to the Magistrate.

(2) No police officer shall investigate a non-cognizable case without the order of a Magistrate having power to try such case or commit the case for trial.

(3) Any police officer receiving such order may exercise the same powers in respect of the investigation (except the power to arrest without warrant) as an officer in charge of a police station may exercise in a cognizable case.

(4) Where a case relates to two or more offences of which at least one is cognizable, the case shall be deemed to be a cognizable case, notwithstanding that the other offences are non-cognizable.

So section 155 is in four parts :

Firstly :- Sub-section (1) empowers the officer in charge of Police Station to record the information and enjoins that informant shall be referred to Magistrate.

Secondly :- Sub-section (2) expressly prohibits the police officer from investigating non-cognizable case without the order of a Magistrate

Thirdly :- Sub-section (3) says as to how Police Officer will proceed when he gets the order of Magistrate. It is by virtue of this provision a police officer can investigate a non-cognizable case

Fourthly :- Sub-section (4) expressly provides that if one of the offences reported is cognizable and the report relate to two or more offences, then case must be treated as cognizable case which means powers and duties under section 154 will be attracted under section 155 as well.

Ans. Investigation in cognizable cases. - Section 156 authorises an officer- in-charge of a police station to make an investigation in any cognizable offence. It provides :-

(1) Any officer-in-charge of a police station may, without the order of a Magistrate, investigate any cognizable case which a court having jurisdiction over the local area within the limits of such station would have power to inquire into or try under the provisions of Chapter XIII.

(2) No proceeding of a police officer in any such case shall at any stage be called in question on the ground that the case was one which such officer was not empowered under this section to investigate.

(3) Any Magistrate empowered under Section 190 may order such an investigation as above mentioned.

In Eastern Spinning Mills v. Rajiv Poddar, AIR 1985 SC 1668, it was observed that Police have a statutory right to investigate the circumstances of an alleged cognizable crime without requiring any authority from the judicial authorities and neither Magistrate nor even the High Court can interfere with those statutory rights by an exercise of the inherent jurisdiction of Court. Except in exceptional cases where non-interference would result in miscarriage of justice, the courts should not interfere at the stage of investigation of offences.

In State of Assam v. Abdul Moor, AIR 1970 SC 1365. A magistrate is empowered under section 156 (3) to refer the case for investigation by Police. But he can do so under this provision only before he has taken cognizance of the case. If he has already taken the cognizance then the investigation can be ordered under section 202 of Code.

Procedure where cognizable offence suspected. - Section 157 provides the manner in which investigation is to be conducted where the commission of a cognizable offence is suspected. It lays down :-

(1) If, from information received or otherwise, an officer-in-charge of a police station has reason to suspect the commission of an offence which he is empowered under Section 156 to investigate, he shall forthwith send a report of the same to Magistrate empowered to take cognizance of such offence upon a police report and shall proceed in person, or shall depute one of his subordinate officers not being below such rank as the State Government may, by general or special order, prescribe in this behalf, to proceed, to the spot, to investigate the facts and circumstances of the case, and, if necessary, to take measures for the discovery and arrest of the offender.

(a) Where local investigation dispensed with. - When any information as to commission of any such offences is given against any person by name and the case is not of a serious nature, the officer-in-charge of police station need not proceed in person or depute a subordinate officer to make an investigation on the spot.

(b) Where police officer-in-charge sees no sufficient ground for investigation. - If it appears to the officer-in-charge of the police station that there is no sufficient ground for entering on an investigation, he shall not investigate the case.

(2) In each of the cases mentioned in clauses (a) and (b) of the proviso to Sub-section (1), officer-in-charge of the police station shall state in his report his reasons for not fully complying with the requirements of that Sub- section, and in the case mentioned in clause (b) of the said proviso, the officer shall also forthwith notify to the informant, if any, in such manner as may be prescribed by the State Government, the fact that he will not investigate the case or cause it to be investigated.

Section 158 makes provisions as to the submission of a report under Section 157. It says :

(1) Every report sent to a Magistrate under Section 157 shall, if the State Government so directs, be submitted through such superior officer of police as the State Government, by general or special order, appoints in that behalf.

(2) Such superior officer may give such instruction to the officer- in-charge of a police station as he thinks fit, and shall, after recording such instructions on such report transmit the same without delay to the Magistrate.

Section 159 provides that such Magistrate, on receiving such report, may direct an investigation, or, if he thinks fit, at once proceed, or depute any Magistrate subordinate to him to proceed, to hold a preliminary inquiry into, or otherwise to dispose of, the case in the manner provided in the Code.

In S.N. Sharma v. Bipen Kumar Tiwari, 1970 SCC (Cri) 258, it was observed that Section 159 is primarily meant to give the magistrate the power of directing an investigation in cases in which the police decide not to investigate the case under the proviso to Section 157(1). It is only in those cases that if magistrate thinks fit, he may himself make an investigation or direct a subordinate Magistrate to hold a preliminary enquiry. The Section is really intended to give a limited power to Magistrate to ensure that the Police investigate all cognizable offences and do not refuse to do so by abusing their power for certain limited cases.

Attendance and examination of witness. - Section 160 is meant to provide facility for the police to obtain evidence with regard to the crime which is being investigated and to secure attendance of person who could supply the necessary information in regard to the commission of the offence. It provides that any police officer making an investigation may, by order in writing, require the attendance before himself of any person being within the limits of his own or any adjoining station who, from the information given or otherwise appears to be acquainted with the circumstances of the case; and such person shall attend as so required :

Provided that no male person under the age of fifteen years or woman shall be required to attend at any place other than the place in which such male person or woman resides.

Examination of witness by police. - The Police have the power to examine witnesses during the course of an investigation. Section 161 lays down

(1) Any police officer making an investigation under this Chapter, or any police officer not below such rank as the State Government may, by general or special order, prescribe in this behalf, acting on the requisition of such officer, may examine orally any person supposed to be with the facts and circumstances of the case.

(2) Such person shall be bound to answer truly all the questions relating to such case put to him by such officer other than questions the answers to which would have a tendency to expose him to a criminal charge to a penalty or forfeiture.

(3) The police officer may reduce into writing any statement made to him in the course of an examination under this section; and if he does so, he shall make a separate and true record of the statement of each such person whose statement he records.

Statement to Police and the use of such statements. - Section 162 makes provisions to keep out evidence which it is suggested is not free and of a fair nature but may have been induced by some form of police duress. It lays down :

(1) No statement, made by any person to a police officer in the course of an investigation, under this Chapter, shall, if reduced into writing, be signed by the person making it; nor shall any such statement, or any record thereof, whether in police diary or otherwise, or any part of such statement on record, be used for any purposes, save as hereinafter provided, at any inquiry or trial in respect of any offence under investigation at the time when such statement was made :

Provided that when any witness is called for the prosecution in such inquiry or trial whose statement has been reduced into writing as aforesaid, any part of his statement, if duly proved may be used by the accused, and with the permission of the Court, by the prosecution, to contradict such witness in the manner provided by Section 145 of the Indian Evidence Act, 1872 (1 of 1872); and when any part of such statement is so used, any part thereof may also be used in the re-examination of such witness, but for the purpose only of explaining any matter referred to in his cross-examination.

(2) Nothing in this section shall be deemed to apply to any statement falling within the provisions of section 32, clause (1) of the Indian Evidence Act, 1872, or to affect the provisions of Section 27 of that Act.

Ans. Sections 160 and 161 of Code of Criminal Procedure provide for interrogation and examination of witnesses by Police Officer during Investigation. Object of these Sections is to provide facility for Police Officer to obtain evidence in respect of crime under investigation. Section 160 of Code lays down that any police officer investigating a case, may require the attendance before himself of any person being within the limits of his own or of adjoining station, who appears to be acquainted with the facts and circumstances of the case. However Police Officer can not require to appear following persons before him:

(i) A male under the age of 15 years

(ii) A female.

In State of A.P. v. Venugopal AIR 1964 SC 33 it was held that power of police officer to require the attendance of `any person' by an order in writing under Section 160 Cr.P.C., for eliciting any information includes accused as well. But beating the accused or any person to extract the information is not permissible.

The Supreme Court in Nandini Sathpathy v. P.L. Dhani, A.I.R. 1978 S.C. 1025 held that the act of directing a woman to appear in police station is violative of Section 160(1) of Cr.P.C. The State Government may, by Rules made in this behalf, provide for the payment by the police officer of the reasonable expenses of every person, attending under Sub-section (1) at any place other than his residence.

The Police have the power to examine witnesses during the course of an investigation. Section 161 lays down:

(1) Any police officer making an investigation under this Chapter, or any police officer not below such rank as the State Government may, by general or special Order, prescribe in this behalf, acting on the requisition of such officer, may examine orally any person supposed to be acquainted with the facts and circumstances of the case.

(2) Such person shall be bound to answer truly all the questions relating to such case put to him by such officer other than questions the answers to which would have a tendency to expose him to a criminal charge or to a penalty of forfeiture.

(3) The police officer may reduce into writing any statement made to him in the course of an examination under this Section ; and if he does so, he shall make a separate and true record of the statement he records .

Ans. Section 164 of Code of Criminal Procedure, lays down the procedure to be adopted by a Magistrate, while recording any confession of accused or statement of a witness, during investigation. Section 164 says-

"(1) Any Metropolitan Magistrate or Judicial Magistrate may, whether or not he has jurisdiction in the case, record any confession or statement made to him in the course of an investigation under this Chapter or under any law for the time being in force, or at any time afterwards before the commencement of the inquiry or trial:

Provided that no confession shall be recorded by a police officer on whom any power of a Magistrate has been conferred under any law for the time being in force.

(2) The Magistrate shall, before recording any such confession, explain to the person making it that he is not bound to make a confession and that, if he does so, it may be used as evidence against him; and the Magistrate shall not record any such confession unless, upon questioning the person making it, he has reason to believe that it is being made voluntarily.

(3) If at any time before the confession is recorded, the person appearing before the Magistrate states that he is not willing to make the confession, the Magistrate shall not authorise the detention of such person in police custody.

(4) Any such confession shall be recorded in the manner provided in Section 281 for recording the examination of an accused person and shall be signed by the person making the confession; and the Magistrate shall make a memorandum at the foot of such record to the following effect :-

"I have explained to (name) that he is not bound to make a confession and that, if he does so, any confession he may make may be used as evidence against him and I believe that this confession was voluntarily made. It was taken in my presence and hearing, and was read over to the person making it and admitted by him to be correct, and it contains a full and true account of the statement made by him.

(Signed) A.B.

Magistrate."

(5) Any statement (other than a confession) made under sub-section (1) shall be recorded in such manner hereinafter provided for the recording of evidence as is, in the opinion of the Magistrate, best fitted to the circumstances of the case; and the Magistrate shall have power to administer oath to the person whose statement is so recorded.

(6) The Magistrate recording a confession or statement under this section shall forward it to the Magistrate by whom the case is to be inquired into or tried."

So Section 164 of Code gives power to Judicial Magistrate to record confession or statement and provides elobrate procedure to be followed by a judicial Magistrate before and while recording the statement. The reason for getting the statements of witnesses recorded under section 164 Cr.P.C. is that they may state on oath so that chances of changing their version at the trial may be minimised for the fear of being involved in perjury.

In Mahabir Singh v. State of Haryana, AIR 2001 SC 2503, it was observed that an accused person can appear before a Magistrate for recording his confession. It is not necessary that such accused should be produced by Police for recording the confession but it is necessary that such appearance must be in course of investigation under chapter XII of Code. If Magistrate does not know that he is concerned in a case for which investigation has been commenced, it is not permissible for him to record confession.

In Sarwan Singh v. State of Punjab, AIR 1987 SC 637, it was held that:

In recording confessions the Magistrate should bear in mind the following principles of law :

(i) Full and adequate compliance with the provisions of this section is imperative. Its non-compliance goes to the root of the Magistrate's jurisdiction to record, and reduces the statement recorded by him to a nullity.

(ii) Every enquiry must be made from the accused as to the custody from which he was produced and as to the custody to which he was to be consigned and the treatment that he had been receiving in such custody in order to ensure that there is no scope for doubt of any sort of extraneous influence; in case the Magistrate discovers on such enquiry that there is ground for such supposition, he should give the accused sufficient time for reflection before he is asked to make his statement.

(iii) Besides the warning specifically provided for in Sub-section (2), namely, that the accused is not bound to make a statement and that if he makes one it may be used against him as evidence, he should also, in plain terms, be assured of protection from any sort of apprehended torture or pressure from such extraneous agents.

(iv) The Magistrate who is entrusted with the duty of recording confession of an accused coming from jail custody or police custody must appreciate his function as one of a judicial officer and must apply his judicial mind to the task of ascertaining that the statement the accused is going to make is of own accord and not on account of any influence on him.

(v) He should also consider it expedient that satisfaction of his conscience as to the voluntary character of the statement is not the only act to be achieved by him, but he should leave such materials of record in proof of compliance with the imperative requirements of Section.

In Bhagwan Singh v. State of M.P., 2003(1) RCR(Criminal) 660 (SC), it was observed by Supreme Court that while recording under section 164, following points must be borne in the mind of Magistrate

(1) Magistrate in particular should ask the accused as to why he wants to make a statement which surely shall go against his interest in the trial;

(2) Accused should be granted sufficient time for reflection;

(3) Accused should be assured of protection from any sort of apprehended torture or pressure from police in case he declines to make a confessional statement;

(4) Confession should be recorded in questions and answers form which is the manner indicated in the criminal court rules;

(5) Before proceeding to record the confessional statement, a searching enquiry must be made from the accused as to the custody from which he was produced and the treatment he had been receiving in such custody in order to ensure that there is no scope for doubt of any sort of extraneous influence.

Ans. Section 57 Cr.P.C. lays down the general Rule that no police officer shall detain in custody a person arrested without warrant for longer period than 24 hours, exclusive of the time necessary for the journey from the place of arrest to the Magistrate's court.

Section 167 of Code prescribe the procedure when investigation of an offence, cannot be completed in 24 hours Sub-section (1) of Section 167 says when an investigation of an offence can not be completed in 24 hours and accusation and information is well founded, police officer is required to send forthwith to nearest Judicial Magistrate, a copy of the entries in the diary and also forward the accused to Magistrate.

Sub-section (2) to Section 167 says that a Magistrate, to whom accused is so forwarded, may authorise the detention of the accused in such custody as such Magistrate thinks fit for term not exceeding 15 days in the whole.

Proviso to Section 167(2) of Code empower the Magistrate to authorise the detention of accused, otherwise than in police custody beyond the period of 15 days if he is satisfied that adequate grounds exist for doing so.

However Magistrate shall not authorise the detention of accused in custody for total period exceeding:

(i) 90 days, where investigation relates to offence punishable with death or imprisonment for life or imprisonment for term not less than 10 years

(ii) 60 days, where investigation relates to any other offence.

On the expiry of above said period and investigation being not completed, Judicial Magistrate of First Class shall grant bail such accused on his furnishing bail bond.

In C.B.I. v. Anupam Kulkarni 1992 Criminal Law Journal 2768, it was held longest period for which an accused can be ordered to be detained in police custody by one or more such order is only fifteen days Provided the Magistrate is satisfied that adequate grounds exist for doing so. But no Magistrate shall authorise the detention of accused in custody under Section 167 for total period exceeding:

(i) 90 days in case of offences under investigation is punishable with death or imprisonment for life or for term not less than 10 years (ii) 60 days where investigation relates to other offences .

The custody after the expiry of first 15 days from date of forwarding the accused to Magistrate can only be judicial custody for rest of the period of 60/90 days

In Kulwinder Kaur v. State of Haryana 2000(2) Recent Criminal Reports 226 Punjab and Haryana High Court held that after the arrest of accused and challan was not put up till the expiry of 90 days and accused applied for bail under Section 167(2) of Code and police putting up the challan before the decision of bail application of accused. This fact will not affect the right of accused to be released on bail.

Ans. What is a police diary. - Section 172 of the Criminal Procedure Code describes the content, and formal set up of a police diary. This diary is called by the name of Police Diary. Every investigating officer shall day by day enter the proceedings of investigation in a diary stating : (I) the time when information reached him (II) the time at which he began and closed his investigation, (III) the place visited by him and (IV) the circumstances ascertained through his investigation.

Any Criminal Court may send for the police diaries of a case under inquiry or trial in such court, and may use such diaries not as evidence in the case, but to aid it in such inquiry or trial.

Object of police diary. - The object of police diary is to enable Courts to check the method of investigation by the police. The early stage of investigation which follow on commission of a crime must necessarily in the vast majority of cases be left to police and until the honesty, the capacity, the direction and judgment of the police can be thoroughly trusted if necessary for the protection of the public against the criminals. The Magistrate or Judge before whom the case is for investigation or for trial should have the means of ascertaining what was the information, true, false or misleading which was obtained from day to day by the police officer who was investigating the case and what was the bares times of investigating upon which the police officer acted. A police diary cannot be used for purpose of contradicting any witnesses other than the police officer who made it.

Use by a police officer. - A Criminal Court may permit a police officer who made the special diary to look at it for purpose of refreshing his memory.

Use by an accused. - The special diary, including every entry in it, is absolutely privileged cannot be used by the accused or his pleadings but he can call for the diary, the police officer making the investigation would omit from the diary matters injurious to the prosecution.

In Mahabir Singh v. State of Haryana, AIR 2001 SC 2503, it was observed that discretion is given to court to use case diary for aiding the court to decide on a point. It is made abundantly clear in Sub-section (2) that court is forbidden from using the entries of such diaries as evidence. What cannot be used as evidence against the accused cannot be used in any other manner against him. If the court use the entries in case diary for contradicting the Police Officer it should be done only in the manner as provided under section 145 of Evidence Act.

Ans. Section 177 of Cr.P.C. lays down a general Rule that every offence shall ordinarily be inquired not and tried by a court within whose local jurisdiction it was committed. Section 178 to 189 embody provisions in the nature of exceptions to Section 177.

2001(2) RCR(Crl.) 381 Mohan Baitha v. State of Bihar The word "Ordinarily" as used in Section 177 of Code indicates that the provision is a general one and must be read subject to the special provisions contained in Criminal Procedure Code - Exceptions implied by word "Ordinarily" need not be limited to those specially provided for by the law and exceptions may be provided by law on consideration of convenience or may be implied from other provisions of law permitting joint trial of offence by the same court.

(a) Section 178 provides that (1) where it is uncertain in which of several local areas an offence was committed or (2) where an offence is committed partly in one local area and partly in another or (3) where offence is a continuing and continue to be committed in more local area than one or (4) where it consists of several acts done in different local areas, the offence may be inquired into and tried by court having jurisdiction over any of such local areas.

(b) Section 179 of Code provide that when an act is an offence by reason of anything which has been done and of a consequence, which has ensued the offence may be inquired into or tried by court within whose local jurisdiction such thing has been done or such consequence has ensued.

So offences contemplated under section 179 are those which are not complete till a special consequence has ensued. The consequence must be an essential ingredient of an offence. In Banwari Lal v. Union of India AIR 1963 SC 1620 Supreme Court held that court having jurisdiction to try the offence of conspiracy has also jurisdiction to try an offence constituted by the acts which are committed in pursuance of conspiracy beyond its jurisdiction and all offences can be tried together jointly.

(c) Section 180 of Code says that when an act is an offence by reason of its relation to any other act which is also offence or which would be an offence if the doer were capable of committing an offence the first mentioned offence may be inquired into an tried by court within whose jurisdiction either act was done.

In State v. Nathumal 1962(1) Cri.L.J. 16, it was held that a charge of abetment may be inquired into or tried either by the Court within the local limits of whose jurisdiction the abetment was committed or by the court within whose local limits the offence abetted was committed.

(d) Section 181(1) says that any offence of being thug or murder committed by a thug or a dacoity or dacoity with murder or of escaping from custody, may be inquired into or tried by court within whose local limits the offence was committed or accused found.

Section 181(2) says offence of kidnaping or abduction of a person may be inquired into or tried by a court within whose local jurisdiction person was kidnapped or abducted or was conveyed or concealed or detained.

Section 181(3) says offence of theft, extortion or robbery may be inquired into or tried by court within whose local jurisdiction the offence was committed or its stolen property was received or retained knowing or having reason to believe it to be stolen property.

Section 181(4) says offence of criminal misappropriation, criminal breach of trust may be inquired into or tried by court within whose local limits offence committed or where any part of such property was received or retained or required to be accounted for by Accused.

Section 181(5) says Any offence which includes the possession of stolen property may inquired into and tried by court within whose local limits offence was committed or where such property was possessed or received or retained it knows it to be stolen property.

Section 182 says Any offence including cheating when deception is practised by means of letters or telecommunication be inquired or tried by court within whose local limits such letter etc. was sent or received or in case of cheating or dishonestly inducing delivery of property where such property was delivered by person deceived or where received by accused.

Section 182(2) says offence punishable under sections 494 and 495 I.P.C. may be inquired or tried by court within whose local limits offence was committed or offender last resided with his or her spouse by first marriage or where wife of first marriage has taken up permanent residence after commission of offence.

Section 183 lays down that if offence is committed in the course of journey or voyage it may be inquired into or tried by court through or into whose local limits the person or thing passed in course of that journey or voyage.

Section 184 of Code makes clear that where offences committed by any person are such that he may be charged with and tried at one trial or the offence committed by several persons are such that they may be tried together the offences may be inquired into and tried by court competent to try any of the offence.

Section 186 says where two or more courts have taken cognizance of some offence and question arises as to which of them ought to inquire and try that offence the question shall be decided if the courts are subordinate to same High Court then by that High Court, if the courts are not subordinate to same High Court then by High Court within whose appellate jurisdiction proceedings were first commenced.

Section 188 of Code provide that Indian Courts are empowered to deal with an offence, committed outside India, if it is committed by

(i) A Citizen of India, whether on the High seas or elsewhere; or

(ii) Person not being such citizen on any ship or aircraft registered in India.

With the previous sanction of Central Govt.

Ans. (i) Section 177 of the Code of Criminal Procedure lays down that every distinct offence shall ordinarily be inquired into and tried by a Court within whose local jurisdiction it was committed. It is a general principle of law that all crime is local. Therefore, the jurisdiction to try an accused for an offence depends upon the crime having been committed within the area of such jurisdiction. But this Rule is neither exclusive nor peremptory.

Section 181(2) of the Code provides that any offence of kidnaping or abduction of a person may be inquired into or tried by a court within whose local jurisdiction the person was kidnapped or abducted or was conveyed or concealed or detained.

In view of the law discussed above, the accused in the present case can be tried either at Lucknow where the offence took place, or at Kanpur from where A is recovered.

(ii) Section 179 of the Code of Criminal Procedure lays down that when an act is an offence by reason of anything which has been done and of a consequence which has ensued, the offence may be inquired into or tried by a Court within whose local jurisdiction such thing has been done or such consequence has ensued. This Section applies only to cases in which the offender is accused of the offence by reason of two things, i.e. some act done by him and some consequence that has ensued from such act. The test to be applied is whether the offenders could have been prosecuted and punished for the offence charged even if the alleged consequence had not ensued. This Section will not apply if the answer is in the affirmative. But it will apply if the answer is in the negative.

In the present case, injuries were caused to X at Lakhimpur, and as a consequence of those injuries he died at Kanpur. Therefore, the offence in this case may be inquired into or tried either at Lakhimpur or Kanpur.

(iii) Section 181(1) of the Code of Criminal Procedure provides that any offence of being a thug, or murder committed by a thug, of dacoity with murder, of belonging to a gang of dacoits, or of escaping from custody, may be inquired into or tried by a Court within whose local jurisdiction the offence was committed or the accused person is found.

In the present case, the offence of dacoity was committed at Patna and the dacoits were arrested at Dhanbad. Therefore, the offence of dacoity can be inquired into or tried either at Patna or Dhanbad.

Ans. Section 190 of Code of Criminal Procedure provides -

"(1) Subject to the provisions of this chapter, any Magistrate of the first class and any Magistrate of the Second class specially empowered in this behalf under Sub-section (2), may take cognizance of any offence -

(a) upon receiving a complaint of facts which constitute such offence;

(b) upon a police report of such facts;

(c) upon information received from any person other than a police officer or upon his own knowledge, that such offence has been committed.

(2) The Chief Judicial Magistrate, may empower any Magistrate of second class to take cognizance under Sub-section (1) of such offences as are within his competence to inquire into or try"

So any Magistrate of First Class and any Magistrate of second class, specially empowered in this behalf by Chief Judicial Magistrate may take cognizance of an offence. The ways in which such cognizance can be taken set out in clauses (a), (b) and (c) of Section 190(1).

In Tula Ram v. Kishore Singh, 1978 Cri.L.J. 8 (SC), it was observed that "Taking Cognizance" means judicial application of the mind of the Magistrate to the facts with a view to taking further action. Thus what section 190 contemplates is that the Magistrate takes cognizance once he makes himself fully conscious and aware of the allegations made in the complaint and decides to examine or test the validity of the said allegations."

Ans. Section 193 of the Code of Criminal Procedure provides: "Except as otherwise expressly provided by this Code or by any other law for the time being in force, no Court of Session shall take cognizance of any offence as a Court of original jurisdiction unless the case has been committed to it by a Magistrate under this Code." Section 194 of the Code explains: "An Additional Sessions Judge or Assistant Sessions Judge shall try such cases as the Sessions Judge of the division may, by general or special Order, make over to him for trial or as the High Court may, by special Order, direct him to try." Section 199(2) of the Code enacts: "Notwithstanding anything contained in this Code, when an offence falling under Chapter XXI of the Indian Penal Code (45 of 1860) is alleged to have been committed against a person who, at the time of such commission, is the President of India, the Vice-President of India, the Governor of a State, the Administrator of a Union territory or a Minister of the Union or of a State or of a Union Territory, or any other public servant in respect of his conduct in the discharge of his public functions a Court of Session may take cognizance of such offence, without the case being committed to it, upon a complaint in writing made by the Public Prosecutor."

Thus, a Court of Session has been empowered to take cognizance of an offence of defamation in certain cases mentioned in Section 199(2) directly on a complaint made by the Public Prosecutor, and without any committal Order. When such complaint is assigned to an Additional Sessions Judge, he can also take cognizance directly.

Ans. The general Rule is that any person having knowledge of the commission of offence may set the law in motion by a complaint even though he is not a person interested in or affected by the offence. To this general Rule Section 195 of Code of Criminal Procedure provides an exception and forbids cognizance being taken of offence referred to therein except where there is a complaint by the court or by public servant concerned.

Section 195(1) lays down :

"No court shall take cognizance:

(a) (i) of any offence punishable under Sections 172 to 188 of I.P.C.

(ii) of any abetment of or attempt to commit such offence or

(iii) of any criminal conspiracy to commit such offence.

except on the complaint in writing of the Public Servant concerned or of some other public servant to whom he is administratively subordinate.

(b) (i) Of any offence punishable under any of the following Sections of the I.P.C. namely Sections 193 to 196, 199, 200, 205 to 211 and 228 when such offence is alleged to have been committed in or in relation to, any proceeding in any court.

(ii) Of any offence described in Section 463 or punishable under Section 471, Section 475 or 476 of said code, when such offence is alleged to have been committed in respect of document produced or given in evidence in a proceeding in any court, or

(iii) Of any criminal conspiracy to commit or attempt to commit or the abetment of any offence specified in Sub-clause (i) or (ii).

except on the complaint in writing of that Court or of some other court to which that court is subordinate."

The object of Section 195 of Code is to prevent improper or reckless prosecution by private persons for offences in connection with the administration of public justice and contempt of lawful authority. Provisions of Section 195 of Code are mandatory and court has no jurisdiction to take cognizance of any offence mentioned therein unless there is a complaint in writing as required by this Section .

Recently Supreme Court in M. S. Ahlawat v. State of Haryana AIR 2000 SC 168 has observed " Section 195 of Criminal Procedure Code provides that where an act amounts to an offence of contempt of the lawful authority of public servants or to an offence against public justice such as giving false evidence under Section 193 I.P.C. etc. or to an offence relating to documents actually used in a court, private prosecutions are barred absolutely and only the court in relation to which the offence was committed or public servant as the case may be, may initiate the proceedings. Provisions of Section 195 Cr.P.C. are mandatory and no court has jurisdiction to take cognizance of any of the offences mentioned therein unless there is a complaint in writing required under that Section _____. While under Section 195 Cr.P.C. it is open to the court before which the offence was committed to prefer a complaint for prosecution of the offender. Section 340 Cr.P.C. prescribes the procedure as to how that complaint may be preferred."

Ans. Section 197(1) of Code of Criminal Procedure says "When any person who is or was a judge, Magistrate or Public Servant, not removable from his office save by the sanction of the Government is accused of any offence alleged to have been committed by him while acting or purporting to act in discharge of his official duty, no court shall take cognizance of such offence except with the previous sanction of Central or State Government as the case may be.

Section 197 embodies one of the exceptions to the general Rule laid down in Section 190 that any offence may be taken cognizance of by Magistrate upon complaint or police report or other information.

The object of Section 197 of Code is to protect judges and Public servants against irresponsible, frivolous or vexatious proceedings for acts done in discharge of official duty and to see that no prosecution is started unless there is some foundation for the charge. Before invoking the Section 197, two conditions must be satisfied:

(1) Public servant is removeable from office either by Union Government, or State Government and not by lesser authority and

(2) He is accused of an offence alleged to have been committed while acting or purporting to act in the discharge of his official duty.

In P.P. Unikrishanan v. Puttiyottil Ali Kutty AIR 2000 SC 2950 Supreme Court had observed that for application of Section 197 of Code "there must be a reasonable connection between the act and the discharge of official duty the act must bear some relation to the duty that the accused could lay a reasonable but not a pretended or fanciful claim that he did it in the course of the performance of his duty."

In Gouri Shankar Prasad v. State of Bihar 2000(2) Recent Criminal Reports 708 (SC) Supreme Court observed:

"The offence alleged to have been committed must have something to do or must be related in some manner with the discharge of official duty, no question of sanction can arise under Section 197 unless the act complained of is an offence, the only point to determine is whether it was committed in discharge of official duty. There must be a reasonable connection between act and official duty. It does not matter even if the act exceeds what is strictly necessary for the discharge of the duty what we must find out is whether the act and the official duty are so interrelated that one can postulate reasonably that it was done by the accused in the performance of the official duty, though possibly in excess of needs and requirements of the situation."

Ans. Section 2(d) of Code defines the term "Complaint" as "Complaint means any allegation made orally or in writing to a Magistrate with a view to his taking action under this Code, that some person known or unknown has committed an offence but does not include police report."

Explanation : A Report made by a Police Officer in a case which discloses, after investigation the commission of a non-cognizable offence shall be deemed to be complaint and police officer by whom such report is made shall be deemed to be a complainant.

In Bhimappa Basappa v. Laxman Shivarayappa, AIR 1970 SC 1153, it was observed that the word `complaint' has wide meaning since it includes even an oral allegation. It may therefore be assumed that no form is prescribed which the complaint must take. It may only be said that there must be an allegation which prima facie discloses the commission of offence with the necessary facts for Magistrate to take action.

So following are essentials for complaint within the meaning of Section 2(d) of Code:

(i) Allegation of commission of an offence.

(ii) Allegation may be made orally or written.

(iii) Allegation made to a Magistrate.

(iv) Allegation made with a view of his taking action under the Cr.P.C.

(v) Allegation may be against a person known or unknown.

(vi) It must not be a police. But report by a police officer, which after investigation discloses commission of non-cognizable offence shall be deemed to be complaint.

PROCEDURE WHEN COMPLAINT IS FILED : Sections 200 to 204 of Code of Criminal Procedure lays down procedure to be adopted by Magistrate on receiving a complaint.

According to Section 200 the procedure to be adopted by a Magistrate on receiving a complaint is

Examination of complainant. A Magistrate taking cognizance of an offence on complaint shall examine upon oath the complainant and the witnesses present, if any, the substance of such examination shall be reduced to writing and shall be signed by the complainant and the witnesses, and also by the Magistrate:

Provided that, when the complaint is made in writing, the Magistrate need not examine the complainant and the witnesses

(a) if a public servant acting or purporting to act in the discharge of his official duties or the Court has made the complaint; or

(b) if the Magistrate makes over the case for inquiry or trial to another Magistrate under Section 192:

Provided further that if the Magistrate makes over the case to another Magistrate under Section 192 after examining the complainant and the witnesses, the latter Magistrate need not examine them.

Where Magistrate not competent to take cognizance of the case. Section 201 provides that if the complaint is made to a Magistrate who is not competent to take cognizance of the offence, he shall

(a) if the complaint is in writing, return it for presentation to the proper court with an endorsement to that effect;

(b) if the complaint is not in writing, direct the complainant to appear before the proper Court.

In Tula Ram v. Kishore Singh AIR 1977 SC 2401, it was held that "After a complaint being filed Magistrate has two alternatives (a) Either to examine the complainant and to proceed under Chapter XV of Code or (b) Direct the Police to Investigate under Section 156(3) of Code, without himself taking cognizance.

(a) Where Magistrate chooses to take cognizance he has to comply with requirement of Section 200 and record the evidence of complainant and his witnesses and then either straightaway issue the process against accused under Section 204 or he can postpone the issue of process and direct an enquiry by any other person or an investigation by police under Section 202. Magistrate after considering the statement of complainant and the witness or result of enquiry or investigation if not satisfied that there are sufficient grounds, he can dismiss the complaint.

(b) Where Magistrate does not take cognizance of matter, he can refer the complaint for Police Investigation under section 156(3) and receives report of police, then either discharge the accused or straightaway issue the process

Section 202(1) of Code says "Any Magistrate on receipt of a complaint of an offence of which he is authorised to take cognizance or which has been made over to him under Section 192, if thinks fit, postpone the issue of process against the accused, and either inquire into the case himself or an investigation to be made by police officer or by such other person as he thinks fit for the purpose of deciding whether there is sufficient ground for proceeding.

According to Section 203, if after considering the statements on oath, of any complainant and of the witnesses and the result of the enquiry or investigation, if any, under Section 202, the Magistrate is of opinion that there is no sufficient ground for proceeding, he shall dismiss the complaint, and in every such case he shall briefly record his reasons for so doing.

In Debender Nath v. State of W.B. AIR 1972 SC 1607 Supreme Court held order of dismissal of a complaint under Section 203 of Code has to be made on judicially sound grounds

Section 204 of Code then provides for issuance of process against accused, when taking cognizance of the offence, is of opinion that there is sufficient ground for proceeding.

In Pepsi Food Ltd. and others v. Special Judicial Magistrate and Other 1998 Supreme Court Cases (Cri) 1400 Supreme Court held "Summoning of an accused in a criminal case is a serious matter. Criminal law cannot be set into motion as a matter of course. The order of Magistrate must reflect that he has applied his mind to facts of case and the law applicable thereto."

Ans. Charge : Framing of `charge' against accused is an important step in a criminal trial. Charge is defined as a precise formulation of the specific accusation made against an accused who is entitled to know its nature at the very earliest stage.

In Manna Lal Khatik v. State of W.B. AIR 1967 Cal. 478, it was observed that `Charge is first notice to prisoner of his offence, it should convey to him in sufficient clearness and certainty what the prosecution intends to prove and which case the accused is to meet.'

The object in framing the charge is to give notice of the essential facts which the prosecution proposes to establish to bring home the charge to the accused so that he may not be prejudiced in his defence.

Sections 211 to 213 of Code of Criminal Procedure set out what a charge must contain.

Section 211 of Code lays down that every charge shall contain the following particulars:

(1) The offence with which the accused is charged.

(2) If the law which creates the offence gives it, any specific name, the offence may be described in the charge by that name.

(3) If the law which creates the offence does not give it any specific name, so much of the definition of the offence must be stated as to give the accused notice of the matter with which he is charged.

(4) The law and the Section of the Law against which the offence is said to have been committed shall be mentioned in the charge.

(5) The fact that charge is made is equivalent to statement that every legal condition required by law to constitute the offence charged was fulfilled in the particular case.

(6) The charge shall be written in the language of the court.

(7) If the accused having been previously convicted of any offence is liable, by reason of such previous conviction to enhanced punishment or to punishment of different kind, for a subsequent offence and it is intended to prove such previous conviction for the purpose of affecting the punishment, which the court may think fit to award for the subsequent offence the fact, date and place of previous conviction shall be stated in charge.

Then Section 212 says that charge shall also contain particulars as to time and place of alleged offence and person against or thing in respect of which it was committed.

According to Section 212(2), when the charge is of criminal breach of trust or criminal misappropriation of money, it shall be sufficient to specify:

(a) the gross sum in respect of which offence is committed.

(b) the dates between which it is committed provided the time between the first and the last date shall not exceed one year.

Section 213 mentions the necessity of particulars of the manner in which the alleged offence was committed. This is however necessary only when the foregoing particulars (as mentioned in Section 211 and 212) do not give the accused sufficient notice of the matter with which he is charged. Section 214 says that in every charge words used in describing an offence shall be deemed to have been used in the sense attached to them respectively by the law under which such offence is punishable.

In R.N. Raghu v. State of Kerala 1988 Criminal Law Journal 1364, it was observed by Kerala High Court "All what accused is entitled to know from the charge framed are

(i) Offence with which he is charge

(ii) Law and Section of Law against which offence is said to have been committed

(iii) Particulars of time and place and person against whom offence is said to have been committed.

Further it is provided under Section 213 of Code that if nature of case is such that those particulars do not give the accused sufficient notice of the matter with which he is charged, such particulars of the manner in which offence alleged was committed, as will be sufficient for that purpose also should be given. The accused is not entitled to any further information.

DEFECTIVE CHARGE Section 215 of Code deals with the cases where a charge is framed but there are errors, omissions or irregularities in the charge. It provides that no error in stating either the offence or the particulars required to be stated in the charge, and no omission to state the offence or those particulars, shall be regarded at any stage of the case as material, unless the accused was in fact misled by such error or omission, and it has occasioned a failure of justice.

Section 215 is intended to prevent any failure of justice for non-compliance with the matters required to be stated in the charge, unless the irregularity in the charge has misled the accused and occasioned a failure of justice, a conviction can not be set aside.

In Bupesh Deb v. State of Tripura AIR 1978 SC 1672, it was observed that Section 215 must be read with Section 465, the combined reading of these provisions require that when any error, omission or irregularity has occurred in the framing of a charge, the only question to consider is whether it has occasioned a failure of justice by prejudicing the accused in defence. Where the prosecution tried to make a case different from that stated in the charge, it clearly causes prejudice to accused.

(b) ALTERATION OF CHARGE Sections 216 and 217 of Code then deal with alteration or addition of charge. Section 216 empowers the court to alter or add to the charge during the course of trial. It is provided that any court may alter or add to any charge at any time before the judgment is pronounced. Every such alteration or addition shall be read and explained to the accused. If the alteration or addition to a charge is such that the proceeding immediately with the trial is not likely, in the opinion of the Court, to prejudice the accused in his defence or the prosecutor in the conduct of the case, the Court may, in its discretion, after such alteration or addition has been made, proceed with the trial as if the altered or added charge had been the original charge.

If the alteration or addition is such that proceeding immediately with the trial is likely, in the opinion of the Court, to prejudice the accused or the prosecutor as aforesaid, the Court may either direct a new trial or adjourn the trial for such period as may be necessary. If the offence stated in the altered or added charge is one for the prosecution of which previous sanction is necessary, the case shall not be proceeded with until such sanction is obtained, unless, sanction has been already obtained for a prosecution on the same facts as those on which the altered or added charge is founded.

According to Section 217, whenever a charge is altered or added to by the Court after the commencement of the trial the prosecutor and the accused shall be allowed :

(a) to recall or resummon, and examine with reference to such alteration or addition any witness who may have been examined, unless the Court, for reasons to be recorded in writing, consider that the prosecutor or the accused, as the case may be, desires to recall or reexamine such witnesses for the purpose of vexation or delay and for defeating the ends of justice;

(b) also to call any further witness whom the court may think to be material.

In Amar Singh v. State of Punjab 1998(4) Recent Criminal Reports 784 Punjab and Haryana High Court has observed "A perusal of Section 217 of Code indicates clearly that whenever charge is altered or added, the prosecutor and the accused had a right to recall for resummon the witness already examined. The exception is that, court for reasons to be recorded in writing may consider that calling of witness would be vexatious and defeat the ends of justice."

Ans. (a) According to Section 218 Cr.P.C. as a matter of general Rule, "For every distinct offence, of which any person is accused there shall be separate charge and every such charge shall be tried separately.

Provided that where the accused person by an application in writing so desires and the Magistrate is of opinion that such person is not likely to be prejudiced thereby, the Magistrate may try together all or any number of charges framed against such person."

The object of Section 218 is to save the accused from being embarrassed in his defence if distinct offences are clubbed together in one charge or in separate charges and tried together. However the legislature has engrafted certain exceptions upon this Rule as contained in Sections 219, 220, 221 and 223 of Code.

Exception No.1 : Three offences of same kind within a year : The first exception is to be in Section 219 which lays that when a person is accused of more offence than one of the same kind committed within the space of twelve months from first to the last of such offences whether in respect of the same person or not, he may be charged with and tried at one trial for any number of them not exceeding three. Section 219(2) says offences are of same kind when they are punishable with the same amount of punishment under the same Section of I.P.C. or any special or local law.

Provided that for the purpose of this Section, an offence under section 379 of I.P.C. shall be deemed to be an offence of the same kind as an offence punishable under Section 380 of the said Code and that an offence punishable under any Section of the Indian Penal Code or of any special or local law shall be deemed to an offence of the same kind as an attempt to commit such offence when such an attempt is an offence.

2. Trial for more than one offence. Section 220 provides another exception to the application of the Rule laid down under Section 218. According to Sub-section (1) if, in one series of acts so connected together as to form the same transaction, more offences than one are committed by the same person, he may be charged with and tried at one trial for every such offence.

3. Sub-section (2) of Section 220 provides that when a person is charged with one or more offences of criminal breach of trust or dishonest misappropriation of property, is also accused of committing for the purpose of facilitating or concealing the commission of that offence or those offences, one or more offences of falsification of accounts, he may be charged with and tried at one trial for every such offence. Thus, embezzlement and falsification of accounts for the purpose of concealing the embezzlement form one transaction.

4. Offences falling within two definitions. Section 220(3) lays down that if the facts alleged constitute an offence falling within two or more separate definitions of any law in force for the time being by which offences are defined or punished, the person accused of them may be charged with, and tried at one trial for, each of such of offences

5. Section 220(4) of Code says If several acts of which one or more than one would by itself or themselves constitute an offence, constitute when combined a different offence, person accused of them may be charged with and tried at one trial for the offence constituted by such acts when combined and for any offence constituted by any one or more of such acts

In Mohinder Singh v. State of Punjab 1999 Criminal Law Journal 263 (SC) Supreme Court observed "Provisions of Section 220 of Code are enabling provision which permits the court to try more than one offence in one trial. The Court may or may not try all the offences together in one trial."

6. Sub-section (1) to Section 221 then lays down that if single act or series of acts is of such a nature that it is doubtful as to which of several offences the facts, which can be proved `will constitute' the accused may be charged with having committed all or any of such offences and any number of such charges may be tried at once or he may be charged in the alternative with having committed someone of said offences

Ans. (b)(i) Section 218(1) of Code of Criminal Procedure lays down the general Rule that "for every distinct offence of which any person is accused, there shall be a separate charge and every such charge shall be tried separately."

Sub-section (2) to Section 218 says nothing in Sub-section (1) shall affect the operation of provisions of Sections 219, 220, 221 and 223.

So provisions of Sections 219, 220 and 221 are exception to general Rule as provided by Section 218.

Section 219 provides that when a person is accused of more offences than one of the same kind committed within the space of twelve months from the first to the last of such offences, whether in respect of the same person or not, he may be charged with, and tried at one trial for, any number of them not exceeding three. The proviso to Section 219 explains that for the purposes of this Section , an offence punishable under Section 379 of the Indian Penal Code shall be deemed to be an offence of the same kind as an offence punishable under Section 380 of the Code.

Thus, an accused can only be charged and tried at one trial for any number of offences of the same kind not exceeding three committed within one year. An accused cannot be tried for more than three offences at one trial. Consequently, there cannot be any joinder of four offences of theft at one trial.

(ii) Section 220(1) of Code of Criminal Procedure says "If in one series of acts so connected together as to form the same transaction, more offence than one are committed by the same person he may be charged with and tried at one trial for every such offence."

Supreme Court in Balbir Singh v. State of Haryana AIR 2000 SC 11 has observed that "Expression `same transaction' is not akin to saying `in respect of same subject matter, there must be commonality of purpose and design and continuity of action".

In case in hand, the transaction is that of rescuing B from his custody of police. To achieve that object, the accused causes grievous hurt to constable C and simple hurt to constable D. So A, in continuation of his action to rescue B from Police custody, committed offence of causing grievous hurt and simple hurt to C and D in the same transaction, therefore A in view of Section 220(1) of Cr.P.C. shall be charged and tried together for offences punishable under Sections 323, 325, 333 of I.P.C. (See Illust. (a) of Sub-section (1) of Section 220).

Ans. The fundamental principle underlying Sections 218 to 221 is that an accused person can be convicted of particular offence only if he was charged with the same. Exceptions to this principle are laid down by Sub-section (2) to Section 221 and Section 222 of Code.

Section 221 of Code says : (1) If a single act or series of acts is of such a nature that it is doubtful which of several offences the facts which can be proved will constitute, the accused may be charged with having committed all or any of such offences, and any number of such charges may be tried at once; or he may be charged in the alternative with having committed some one of the said offences.

(2) If in such a case the accused is charged with one offence, and it appears in evidence that he committed a different offence for which he might have been charged under the provisions of Sub-section (1), he may be convicted of the offence which he is shown to have committed, although he was not charged with it.

So provisions of Section 221 are clear enough to enable the court to convict an accused person even of an offence with which he had not been charged, if the court is of opinion that provision of Sub-section (1) apply to case, that is to say if a single act is or a series of acts are of such a nature that it is doubtful which of several offences, the facts of which can be proved, will constitute, then accused can be charged with having committed all or any of such offences and any number of such charges can be tried at once and by virtue of provisions of Sub-section (2), the accused though charged with one offence and it appears in evidence that he committed a different offence for which, he might not have been charged, he can be convicted of the offence which is shown to have committed.

In Nanak Chand v. State of Punjab, AIR 1955 SC 274, : Supreme Court held that Section 221 is entirely dependent on the provisions of Sub-section (1) of Section 221. The provisions of Sub-section (1) can apply only in cases where there is no doubt about the facts which can be proved but a doubt arises as to which of several offences have been committed on the proved facts in which case any number of charges can be framed. In these circumstances if there had been an omission to frame a charge, then under Sub-section (2) the conviction could be arrived at on the evidence although no charge had been framed.

Then Section 222 of Code says: When a person charged with an offence consisting of several particulars, a combination of some only of which constitutes a complete minor offence, and such combination is proved, but the remaining particulars are not proved he may be convicted of the minor offence, though he was not charged with it. [Section 222(1)].

When a person is charged with an offence and the facts are proved which reduce it to minor offence, he may be convicted of the minor offence, though he was not charged with it. [Section 222(2)].

When a person is charged with an offence, he may be convicted of an attempt to commit such offence, although the attempt is not separately charged. [Section 222(3)].

Nothing in this Section shall be deemed to authorise a conviction of any minor offence where the conditions requisite for the initiation of proceedings in respect of that minor offence have not been satisfied.[Section 222 (4)].

Ans. Section 221 of the Code of Criminal Procedure provides as under:

"(1) If a single act or series of acts is of such a nature that it is doubtful which of several offences the facts which can be proved will constitute, the accused may be charged with having committed all or any such offences, and any number of such charges may be tried at once; or he may be charged in the alternative with having committed some one of the said offences.

(2) If in such a case the accused is charged with one offence, and it appears in evidence that he committed a different offence for which he might have been charged under the provisions of Sub-section (1), he may be convicted of the offence which he is shown to have committed, although he was not charged with it.

The provisions of the two Sub-sections are clear enough to enable a Court to convict an accused person even of an offence with which he has not been charged if the Court is of the opinion that the provisions do apply, so that for want of a specific charge there should not be a failure of justice.

In Sunil v. State, AIR 1965 SC 706, it was held by the Supreme Court that where a public servant is charged and tried by the Special Court for an offence under Section 409, I.P.C., but a charge under Section 420, I.P.C., could be framed by the Court under Section 221 on the basis of the allegations in the chargesheet, the trial Court or the appellate Court can, in law, convict the accused of an offence under Section 420, I.P.C. instead of Section 409, I.P.C., if it be of the view that the offence of cheating has been established. This would accord with the provisions of Section 221 of the Code.

Ans. Joinder of Accused Persons : The normal Rule under the Criminal Procedure Code is to try each accused separately when the offence committed by him is distinct and separate. In State of Andhra Pradesh v. Ganeshwara Rao, AIR 1963 SC 1850, it was held by the Supreme Court that separate trial is the normal Rule and joint trial is an exception when the accused have committed separate offences. Section 223 of the Code of Criminal Procedure provides that the following persons may be charged and tried together, namely:

(a) persons accused of the same offence committed in the course of the same transaction;

(b) persons accused of an offence and persons accused of abetment of, or an attempt to commit, such offence;

(c) persons accused of more than one offence of the same kind within the meaning of Section 219 committed by them jointly within the period of twelve months;

(d) persons accused of different offences committed in the course of the same transaction;

(e) persons accused of an offence which includes theft, extortion, cheating, or criminal misappropriation, and persons accused of receiving or retaining, or assisting in the disposal or concealment of, property possession of which is alleged to have been transferred by any such offence committed by the first named persons, or of abetment of or attempting to commit any such last named offence;

(f) persons accused of offences under Sections 411 and 414 of the Indian Penal Code, or either of those Sections in respect of stolen property the possession of which has been transferred by one offence;

(g) persons accused of any offence under Chapter XII of the Indian Penal Code, relating to counterfeit coin and persons accused of any other offence under the said Chapter relating to the same coin, or of abetment of or attempting to commit any such offence, and the provisions contained in the former part of this Chapter shall, so far as may, apply to all such charges:

Provided that where a number of persons are charged with separate offences and such persons do not fall within any of the categories specified in this Section, the Magistrate may, if such persons by way of application in writing, so desire, and if he is satisfied that such persons would not be prejudicially affected thereby, and it is expedient so to do, try such persons together.

Recently Supreme Court while dealing with Section 223 of Cr.P.C. in Balbir v. State of Haryana AIR 2000 SC 11 has observed:

"As per Section 223 all persons falling under any of the seven categories enumerated therein can be charged and tried together. In clauses (a) and (d) of Section 223 the primary condition is that persons should have been accused either of the same offence or of different offences "committed in course of same transaction." That expression is not akin to saying "in respect of same subject matter". Where there is continuity of action, then all those persons involved can be accused of the same or different offences, committed in course of same transaction. But if in one case the accused is alleged to have killed a person without any junction with the Accused in other case, then it can not be treated as same offence or even different offence "committed in course of same transaction."

Ans. Criminal Procedure Code 1973 has classified trials into two groups namely Session Trial and Magistrate Trial, depending on the gravity of the offences and punishment prescribed therefor. The first schedule of the Code of Criminal Procedure 1973 is divided in two parts First part of the schedule through its column No. 6 gives out list of offences under I.P.C. and shows which of them are triable by Court of Session or Court of Magistrate. Second part of this schedule deals with the offences against other law.

Chapter XVIII of Code consisting of Sections 225 to 237 deal with procedure in trial by court of Session.

According to Section 225 in every trial before court of Session, the prosecution shall be conducted by Public Prosecutor. Section 226 lays down that when the accused appears or is brought before the court in pursuance of a commitment of the case under Section 209, the prosecutor shall open his case by describing the charge brought against the accused and stating by what evidence he proposes to prove the guilt of accused.

Section 227 of Code then provides if upon consideration of the record of the case and documents submitted therewith and after hearing the submissions of the accused and the prosecution in this behalf, the Judge considers that there is no sufficient ground for proceeding against the accused, he shall discharge the accused and record his reason for so doing.

According to Section 228, if the Judge after such consideration and hearing is of opinion that there is ground for presuming that the accused has committed an offence which (a) is not exclusively triable by the Court of Session, He may frame a charge against the accused and by order transfer the case for trial to Chief Judicial Magistrate and thereupon the Chief Judicial Magistrate shall try the offence in accordance with the procedure for trial of warrant case instituted on Police Report. (b) is exclusively triable by the court; he shall frame in writing a charge against accused and then accused shall be asked whether he pleads guilty of the offence charged or claims to be tried.

In State of Delhi v. Gan Devi AIR 2001 SC 40, Supreme Court observed that Legal Position is well settled that at the stage of framing of charge trial Court is not to examine and assess in detail, the materials, placed on record by prosecution, nor is it for court to consider sufficiency of materials to establish the offence alleged against the accused. At the stage of charge, court is to examine the materials only with a view to be satisfied that prima facie case of commission of offence alleged, against the accused has been made out.

Then Section 229 lays down that if accused pleads guilty, the Judge shall record the plea and may in his discretion convict him thereon. Then Section 230 says that if the accused refuses to plead or does not plead guilty or claims to be tried or is not convicted under Section 229, the Judge shall fix a date for examination of witnesses and an application of prosecution, may issue any process for compelling the attendance of any witness or the production of any document or thing. Then Section 231 of Code provides that on the date so fixed, the Judge shall proceed to take all such evidence as may be produced in support of prosecution. The Judge may in his discretion, permit the cross examination of any witness to be deferred until any other witness or witnesses have been examined or recall any witness for further cross examination.

In Bava Hajeer v. State of Kerala 1974 Criminal Law Journal 755 (SC) Supreme Court held "It is undoubtedly the duty of prosecution to lay before the court all material evidence available to it, which is necessary for unfolding its case but it would be unsound to lay down as general Rule that every witness must be examined even though his evidence may not be very material or even if it is known that he has been won over or terrorised.

According to Section 232, if after taking the evidence for the prosecution, examining the accused and hearing the prosecution and the defence on the point the Judge considers that there is no evidence that the accused committed the offence the Judge shall record an order of acquittal.

Section 233 lays down further procedure where the accused is not acquitted under Section 232. It says that in such case the accused shall be called upon to enter on his defence and adduce any evidence he may have in support thereof. If the accused puts in any written statement, the Judge shall file it with the record. If the accused applies for the issue of any process for compelling the attendance of any witness or the production of any document or thing the Judge shall issue such process unless he considers, for reasons to be recorded, that such application should be refused on the ground that it is made for the purpose of vexation or delay or for defeating the ends of justice.

It is the duty of the court to call upon the accused to enter his defence and produce evidence for that. Any denial of this right to lead evidence in support of defence would vitiate the whole trial.

Section 234 further provides that when the examination of the witness, if any, for the defence is complete, the prosecutor shall sum up his case and the accused or his pleader shall be entitled to reply, provided that where any point of law is raised by the accused or his pleader the prosecution may, with the permission of the Judge make his submission with regard to such point of law. Then comes the stage of judgement. According to Section 235, after hearing arguments and points of law, if any, the Judge shall give a judgment in the case. If the accused is convicted, the Judge shall, unless he proceeds in accordance with the provisions of Section 360, hear the accused on the question of sentence and then pass sentence on him according to law.

Then Section 236 of Code provides that in case where previous conviction is charged and the accused does not admit that he has been previously convicted, as alleged in the charge, the Judge may after he has convicted the accused, take evidence in respect of the alleged previous conviction and shall record a finding thereon.

Ans. Warrant Case. Section 2(x) of Code of Criminal Procedure says `Warrant case means a case relating to an offence, punishable with the death, imprisonment for life or imprisonment for term exceeding 2 years.

TRIAL OF WARRANT CASE INSTITUTED ON POLICE REPORT In trial of warrant cases instituted on police report, the Magistrate has to follow the procedure specified in Sections 238 to 243 and Section 248 of the Code.

According to Section 238, when accused appears or is brought before Magistrate for trial, the Magistrate shall satisfy himself that he has complied with provisions of Section 207 of Code i.e. accused has been supplied with copies of police report and other documents. The next stage for the Magistrate, as provided by Section 239, shall be to consider all the documents placed before him under Section 173 and if after making such examination, if any, of the accused as he considers necessary and giving the prosecution an opportunity of being heard, he considers the charge to be groundless, he shall discharge the accused and record his reasons for doing so.

In Kanti Bhadra Shah and Other v. State of W.B. AIR 2000 SC 522, Supreme Court has held that "If the trial court decides to frame charges there is no legal requirement that he should pass an order specifying the reasons as to why he opts to do so. Framing of charge itself prima facie shows that trial Judge has formed the opinion upon considering the police report and other documents and after hearing both the parties that there is ground for presuming that accused has committed the offence. It is only where Magistrate decides to discharge the Accused under Section 239 of Code or under Section 245, he is obliged to record his reasons for discharging the accused.

As laid down by Section 240, if there is ground for presuming that the accused has committed an offence, the Magistrate shall frame a charge against the accused if the following conditions are satisfied:

(a) the offence is triable as a warrant case,

(b) it is triable by him, and

(c) he can adequately punish the accused.

Section 240(2) provides that the charge shall then be read and explained to the accused and he shall be asked whether he pleads guilty or claims to be tried.

Under Section 241 the Magistrate has a discretion to convict an accused who pleads guilty. The plea of guilty must be clear and unambiguous and must be recorded as nearly as possible in the very words of the accused. The recording of the plea of guilty is mandatory and a conviction based on the alleged plea of guilty without specifically recording it invalidates the trial and the conviction based thereon.

Section 242 lays down that if the accused

(i) refuses to plead, or

(ii) does not plead guilty, or

(iii) claims to be tried, or

(iv) the Magistrate does not convict him on his plea of guilty, a date shall be fixed for the examination of the witnesses.

The Magistrate may, on an application of the prosecution, issue summons to any prosecution witness to attend or produce any document or thing. On such date the Magistrate shall proceed to take all such evidence as may be produced in support of the prosecution; he may permit the cross-examination of any witness to be deferred until any other witness or witnesses have been examined or recall any witness for further examination.

The accused shall then, under Section 243, enter upon his defence and the written statement, if any, shall be filed with the record. After entering upon defence if the accused applies for the issue of process for the attendance of any witnesses, for examination or cross-examination or the production of any document or thing, the Magistrate shall issue such process unless he considers the application to be vexatious, or to be such as to cause delay or defeat the ends of justice. No witness, already cross-examined or in respect of whom an opportunity for cross-examination has been given to the accused shall be so compelled to attend, unless the Magistrate is satisfied that it is necessary for justice. The accused may be required to deposit the necessary expenses of any witness so recalled before he is summoned.

In Basava Raj R. Patil v. State of Karnataka 2000 (4) Recent Criminal Reports 543 (SC) Supreme Court has held that Section 243(1) of Code enables the accused who is involved in the trial of warrant case instituted on police report to put in any written statement. When any such statement is filed, the court is obliged to make it part of the Record of the case, even if such case is not instituted on police report, the accused has the same right in Section 247. Even accused involved in offences exclusively triable by court of Session, can also exercise such right to put in written statement under section 233(2) of Code.

Section 248 which relates to judgment applies alike to police and non-police cases . If the Magistrate finds the accused not guilty, he shall record an order of acquittal, otherwise he shall sentence him according to law after hearing him on the question of sentence. He may not pass a sentence if he releases the accused on probation of good conduct under Section 360 or submits the proceedings under Section 325, for a severer punishment which he himself is not empowered to inflict, to the Chief Judicial Magistrate. If the accused does not admit his previous convictions, evidence of previous conviction shall be taken after the Magistrate has convicted the accused.

Ans. Section 2(w) of Criminal Procedure Code lays down that "Summon Case" means a case relating to an offence and not being warrant case. Then Section 2(x) lays down that "Warrant Case" means a case relating to an offence punishable with death, imprisonment for life or imprisonment for a term exceeding two years "

So the division of cases into summons and warrant cases is based on punishment which can be awarded. Those cases which are punishable with imprisonment for two years and under are summons cases and the rest are all warrant cases

The procedure for the trial for warrant cases is dealt with in Chapter XIX of Code. Sections 238 to 243 provide procedure in respect of trial of Warrant Cases, instituted on Police Report and Sections 244 to 247 deal with procedure of Warrant cases instituted on complaint and Sections 248 to 250 deal with the conclusion of warrant case trial.

PROCEDURE OF TRIAL OF WARRANT CASE INSTITUTED ON COMPLAINT Section 244 of Code lays down that when in a warrant case instituted otherwise than on police report, the accused appears or brought before Magistrate, the Magistrate shall proceed to hear the prosecution and take all such evidence as may be produced in support of prosecution. Sub-section (2) then says that Magistrate may exercise his discretion in issuing summons to any of the prosecution witness directing him to attend or to produce document or other thing. Section 245 of Code then provide that if upon taking all evidence referred to in Section 244, the Magistrate considers for reasons to be recorded that no case against the accused has been made out, which if unrebutted would warrant his conviction, the Magistrate shall discharge him. In Ratilal Bhanji Mithani v. State of Maharashtra AIR 1979 SC 94 Supreme Court held that "In a warrant case instituted otherwise than on police report "discharge" and "acquittal" are two different concepts applicable to different stages of the proceedings in court. An order of discharge in a warrant case instituted on complaint can be made only after the process has been issued and before charge is framed. Section 245(1) shows that as a general Rule there can be no order of discharge unless the evidence of complainant (Prosecution Witnesses) has been taken and the Magistrate considers for reasons to be recorded in the light of the evidence that no case has been made out. Sub-section (2) to Section 245 which authorises the Magistrate to discharge the accused at any previous stage of the case if he considers the charge to be groundless is an exception to that Rule. As a general Rule, a discharge without considering the evidence taken is illegal.... Once the charge is framed, the Magistrate has no power to cancel the charge or reverse the proceedings to the stage of Section 245 and discharge the accused. The trial in warrant cases treat with the framing of charge, prior to it, the proceedings are only an inquiry."

Section 246(1) of Code provide that if Magistrate is of opinion that there is ground for presuming that the accused has committed an offence, which such Magistrate is competent to try and which in his opinion could be adequately punished by him, he shall frame in writing charges against the accused. Section 246(2) says that the charge shall be read over and explained to the accused and he shall be asked whether he pleads guilty or not and if the accused plead guilty, the Magistrate shall record the plea and may in his discretion convict him thereon (Sub-section (3)). If the Accused refuses to plead or claimed to the tried, then accused shall be required to state whether he wishes to cross examine any and if so which of the witnesses for the prosecution whose evidence has been taken. If Accused says he so wishes, the witnesses named by him shall be recalled and after their cross examination or re-examination they shall be discharged.

Section 247 then provide that the Accused shall be called upon to enter upon his defence and produce his evidence and if Accused puts in any written statement, the Magistrate shall file it with the record and upon application of Accused, Magistrate shall issue process for compelling appearance of any witness for examination unless Magistrate refuses such application on the ground of vexation.

Section 248 then says that if the charge against accused was framed and Magistrate finds that the accused is not guilty, he shall record the order of his acquittal and if he finds the accused guilty but does not proceed in accordance with provisions of Sections 325 or 360, he shall, after hearing the accused on the question of sentence, pass sentence upon him. Where the accused has been charged with, on previous convictions, which he has denied, Magistrate shall, after he has convicted the accused, take evidence in respect of alleged previous convictions and shall record finding thereon.

Section 249 of Code provides that when proceedings have been instituted upon complaint and if on any date of hearing complainant is absent and offence is compoundable or non-cognizable, then Magistrate may discharge the accused at any time before charge has been framed.

In Karnal Distillery Co. Ltd. v. P.L. Kapoor 1982 Criminal Law Times 26 Punjab and Haryana High Court had observed that Section 249 Cr.P.C. postulates two contingencies in which the complaint may be dismissed on the non-appearance of the complainant. The first contingency is that the offence may be lawfully compounded and the second contingency is that offence should not be a cognizable one. The use of word "or" in the Section in between the two contingencies is clearly indicative of the fact that anyone of these contingencies is enough to empower the court to dismiss a complainant in default."

Section 250 of Code then provides for compensation for accusation without reasonable cause.

Ans. Summon Cases. Section 2(w) of Code says "Summon Case means a case relating to an offence and not being a warrant case." So a summons case means a case relating to an offence punishable with imprisonment upto two years, but not more than two years. The following procedure shall be observed by the Magistrate in the trial of summons cases:

(1) SUBSTANCE OF THE OFFENCE TO BE STATED : Section 251 of Code says when accused appears or brought before the Magistrate, the particulars of the offence of which he is accused shall be stated to him and he shall be asked whether he pleads guilty or has any defence to make, but shall not be necessary to frame a formal charge.

In State of Gujarat v. Lalit Mohan 1990 Criminal Law Journal, 2341 it was observed that it is not incumbent upon a Magistrate to frame a formal charge in a summons cases, but substance of accusation is to be explained, moment the accused is brought before court.

(2) CONVICTION ON ADMISSION : Section 252 of Code then says if the accused pleads guilty, the Magistrate shall record the plea as nearly as possible in the words used by accused and may in his discretion, convict him thereupon.

(3) Conviction on plea of guilty in absence of accused in petty cases As per provisions of Section 253, where a summons has been issued under Section 206 and the accused desires to plead guilty to the charge without appearing before the Magistrate he shall transmit to the Magistrate, by post or by messenger, a letter containing his plea and also the amount of fine specified in the summons. The Magistrate may in his discretion convict the accused in his absence, on his plea of guilty and sentence him to pay the fine specified in the summons and the amount transmitted by the accused shall be adjusted towards that fine, or where a pleader authorised by the accused in this behalf pleads guilty, on behalf of the accused the Magistrate shall record the plea as nearly as possible in the words used by the pleader and may, in his discretion convict the accused on such plea and sentence him as aforesaid.

(4) Procedure, when not convicted. It is provided by Section 254, that (1) If the Magistrate does not convict the accused under Section 252 or Section 253, the Magistrate shall proceed to hear prosecution, and also to hear the accused and take all such evidence as he produces in his defence.

(2) The Magistrate may, if he thinks fit, on the application of the prosecution or the accused, issue a summons to any witness directing him to attend or to produce any document or other thing.

(3) The Magistrate may, before summoning any witness on such application, require that the reasonable expenses of the witness incurred in attending the purposes of the trial be deposited in the Court.

(5) Acquittal. According to Section 255(1), if the Magistrate, upon taking the evidence referred to in Section 254 and such further evidence, if any, as he may, of his own motion, cause to be produced, and (if he thinks fit) examining the accused, finds the accused not guilty, he shall record an order of acquittal.

(6) Conviction Sub-section (2) to Section 255 of Code then provides that where Magistrate does not proceed in accordance with the provisions of Section 325 or Section 360, he shall if he finds the accused guilty pass sentence upon him according to law.

Sub-section (3) to Section 255 enables the Magistrate to convict the accused of any offence which from the facts proved or admitted, appears to have committed, though it is different in its nature from the offence originally charged.

Ans. Section 256 of Code of Criminal Procedure deals with consequence of non-appearance or death of complainant.

The provisions of Section 256 lay down that if the summons has been issued on complaint, and on the day appointed for the appearance of the accused, or any day subsequent thereto to which the hearing may be adjourned, the complainant does not appear, the Magistrate shall, notwithstanding anything here-in-before contained, acquit the accused, unless for some reason he thinks proper to adjourn the hearing of the case to some other day:

Provided that where the complainant is represented by a pleader or by the officer conducting the prosecution or where the Magistrate is of opinion that the personal attendance of the complainant is not necessary, the Magistrate may dispense with his attendance and proceed with the case.

The provisions of Sub-section (1) shall, so far as may be, apply also to the cases where the non-appearance of the complainant is due to death.

The object underlying the Section is to ensure that private complainants are not dilatory in prosecuting criminal proceedings leading to harassment of accused person and waste of public time.

In Associated Cement Co. Ltd. v. Keshvanand, AIR 1998 SC 596, it was observed : Two constraints are imposed on the Court for exercising the power under the Section 256. First is, if the Court thinks that in situation it is proper to adjourn the hearing then the Magistrate shall not acquit the accused. Second is when the Magistrate considers that personal attendance of the complainant is not necessary on that day the Magistrate has the power to dispense with his attendance and proceed with the case. When the Court notices that the complainant is absent on a particular day the Court must consider whether personal attendance of the complainant is essential on that day for the progress of the case and also whether the situation does not justify the case being adjourned the Court is free to dismiss the complaint and acquit the accused. But if the presence of the complainant on that day was quite unnecessary then resorting to the step of axing down the complaint may not be a proper exercise of the power envisaged in the section.

Facts of the case in hand are very similar to facts of case Johri Lal v. Ramji Lal, AIR 1965 Raj. 19. In this complainant was present on as many as eleven hearings, on twelfth the accused was acquitted because of complainant's absence. On that date the complainant had nothing to do. He had deposited process fee for the witnesses being summoned, but summons had not been issued. High Court held that acquittal of accused under these circumstances was arbitrary and capricious and is liable to be set aside. It was observed:

"The power to dismiss the case is undoubtedly there. But power must be exercised judicially and is not intended to serve a shortcut for Magistrate to dismiss cases by snap judgements "

In view of above discussion in the case in hand complaint is not liable to be dismissed because of absence of complainant under section 256 of Code, particularly when complainant was being duly represented by his lawyer and also when there was nothing to be done on that date.

Ans. SUMMARY TRIAL Chapter XXI of Criminal Procedure Code deals with Summary Trial. Section 260 of code says that Chief Judicial Magistrate, Metropolitan Magistrate or Magistrate of First class specifically empowered by High Court may try in a summary way following offences:

(i) Offences not punishable with death or imprisonment for life or for term exceeding 2 years

(ii) Theft, where the value of property stolen does not exceed two hundred rupees

(iii) Receiving or retaining stolen property where value of property does not exceed Rs. 200.

(iv) Offences of assisting in concealing or disposal of stolen property.

(v) Offences under Sections 454 and 456 of I.P.C.

(vi) Offences of insult with the intent to invoke a breach of peace under Section 504 or Criminal intimidation under section 506 of I.P.C.

(vii) Offences in respect of which complaint may be made under Section 20 of Cattle Trespass Act 1871.

Section 260(2) says if during the course of summary trial, it appears to Magistrate that nature of case is such that it is undesirable to try such case summarily, he shall recall any witness who may have been examined and proceed to rehear the case in the manner as provided by code.

In Sham Lal v. State of Punjab 1977 Chandigarh Law Reporter 137 it was observed that "Procedure for summary trial of cases is laid down in Chapter XXI of Code of Criminal Procedure and Section 262 says that even in such trials procedure laid down for summons cases shall be followed if the offence is triable as summons cases and that of warrant cases where the offence is triable as a warrant case. Section 263 prescribes the nature of record that has to be kept in non-appealable cases Though it is stated that in such cases the Magistrate need not to record evidence of witnesses or frame formal charges However particulars of offence complained of and offence proved must be entered on the record.

Ans. According to Sections 273, Cr.P.C., it is general principle that all evidence in trials or other proceedings should be taken in the presence of the accused, or when his personal attendance is dispensed with, in the presence of his pleader. In this section "accused" includes a person in relation to whom any proceeding under Chapter VIII has been commenced under this section. It is provided in Section 272 that the State Government may determine what shall be, for purposes of this Code the language of each Court within the State other than the High Court.

It is laid down in Section 274 that in all summons cases tried before a Magistrate, in all inquiries under Sections 145 to 148 (both inclusive), and in all proceedings under Section 446 otherwise than in the court of trial, the Magistrate shall, as the examination of each witness proceeds, make a memorandum of the substance of his evidence in the language of the Court, provided that if the Magistrate is unable to make such memorandum himself, he shall, after recording the reason of his inability, cause such memorandum to be made in writing or from his dictation in open Court. Such memorandum shall be signed by the Magistrate and shall form part of record.

According to Section 275, in all warrant cases before a Magistrate, the evidence of each witness shall, as his examination proceeds, be taken down in writing either by the Magistrate himself or by his dictation in open court or, where he is unable to do so owing to physical or other incapacity, under his direction and superintendence, by the officer of the Court appointed by him in this behalf. Where the Magistrate causes the evidence to be taken down, he shall record a certificate that the evidence could not be taken down by himself for the reasons referred above. Such evidence shall ordinarily be taken down in the form of a narrative; but the Magistrate may in his discretion take down, or cause to be taken down, any part of such evidence in the form of question and answer. The evidence so taken down shall be signed by the Magistrate and shall form part of the record.

As laid down by Section 276, in all trials before a Court of Session, the evidence of each witness shall, as his examination proceed, be taken down in writing either by the presiding Judge himself or by his dictation in open Court or, under his direction and superintendence, by an officer of the Court appointed by him in this behalf. Such evidence shall ordinarily be taken down in form of narrative; but the presiding Judge may, in his discretion, take down or cause to be taken down, any part of such evidence in the form of question and answer. The evidence so taken own shall be signed by the presiding Judge and shall form part of the record.

It is provided by Section 277 that in every case where evidence is taken down under Section 275 or Section 276 :-

(a) if the witness gives evidence in the language of the Court, it shall be taken down in that language ;

(b) if he gives evidence in any other language, it may, if practicable, be taken down in that language, and it is not practicable to do so, a true translation of the evidence in the language of the Court shall be prepared as the examination of witness proceeds, signed by the Magistrate or presiding Judge and shall form part of the record;

(c) where under clause (b) evidence is taken down in a language other than the language of the court, a true translation thereof in the language of the court shall be prepared as soon as practicable, signed by the Magistrate or the presiding Judge, and shall form part of the record, provided that when under clause (b) evidence is taken down in English and a translation thereof in the language of the Court is not required by any of the parties, the Court may dispense with the translation.

According to Section 278, as the evidence of each witness taken under Section 275 or 276 is completed, it shall be read over to him in the presence of the accused, if in attendance, or of his pleader, if he appears by pleader and shall, if necessary, be corrected. If the witness denies the correctness of any part of the evidence when the same is read over to him, the Magistrate or presiding Judge may, instead of correcting the evidence make a memorandum thereon of the objection made to it by the witness and shall add such remarks as he thinks necessary. If the record of the evidence is in a language different from that in which it has been given and the witness does not understand that language, the record shall be interpreted to him in the language in which it was given, or the language in which he understands.

In Mr. Mohmd. Omar v. State of W.B., AIR 1989 SC 1785, it was observed that the object of section 278 is two fold. Firstly to ensure that evidence of witness as recorded is accurate, secondly to give witness concerned an opportunity to point out mistakes if any. If correction suggested by witness is one which the Judge considers necessary, he will make it at once as required by Sub-section (1) but if correction is such that Judge does not consider necessary, Sub-section (2) requires that a memorandum of objection be made and the Judge and his remarks, if any thereto. Section is not intended to permit a witness to resile from his statement in the name of correction.

Section 279 provides for the interpretation of the evidence to the accused or his pleader, if it is recorded in a language not understood by the accused or his pleader. A Judge or Magistrate is authorised under Section 280 to record not only the evidence of witness but also to record such remarks as he thinks material respecting the demeanor of such witness while under examination. But he is not authorised to record remarks about the credibility or the substance of the deposition of the witness.

When the services of an interpreter are required by any Criminal Court for the interpretation of any evidence or statement he shall be bound to state the true interpretation of such evidence or statement (Section 282).

Ans. Section 292 is another special rule and makes any document purporting to be a report under the hand of any such Gazetted Officer of the Mint or of the India Security Press (including the office of the Controller of Stamps and Stationery) as the Central Government may, by notification specify in this behalf, upon any matter or thing duly submitted to him for examination and report in the course of any proceeding under this Code, may be used as evidence in any inquiry, trial or other proceedings under this Code, although such officer is not called as a witness.

The Court may, if it thinks fit, summon and examine any such officer as the subject-matter of his report; provided that no such officer shall be summoned to produce any records on which the report is based.

Without prejudice to the provisions of Sections 123 and 124 of Indian Evidence Act, 1872, no such officer shall, except with the permission of the Master of the Minor of the India Security Press or the Controller of Stamps and Stationery, as the case may be, permitted --

(a) to give any evidence derived from any unpublished official records on which the report is based; or

(b) to disclose the nature of particulars of any test applied by him in the course of the examination of the matter or thing.

Ans. Section 293 is yet another special rule that makes any document purporting to be a report under the hand of a Government scientific expert to whom this section applies, upon any matter or thing duly submitted to him for examination or analysis and report in the course of any proceeding under this Code, may be used as evidence in any inquiry, trial or other proceeding under this Code.

The Court may, if it thinks fit, summon and examine, any such expert as to the subject-matter of his report.

Section 293 applies to the following Government scientific experts, namely --

(a) any Chemical Examiner or Assistant Chemical Examiner to Government;

(b) the Chief Inspector of Explosive;

(c) the Director of Finger Print Bureau;

(d) the Director, Haffkeine, Institute, Bombay;

(e) the Director, Deputy Director or Assistant Director of Central Forensic Science Laboratory or a State Forensic Science Laboratory;

(f) the Serologist to the Government.

Though there is nothing wrong in taking reports from the Chemical Examiner and the Serologist, but when there is a difference of opinion in the reports, the duty to explain the difference is on the prosecution and the mere production of the report does not prove anything which can weigh against the accused.

Ans. Section 300 of the Code of Criminal Procedure, 1973 lays down that a person who has once been tried by a Court of competent jurisdiction for an offence and convicted or acquitted of such offence shall, while such conviction or acquittal remains in force, not be liable to be tried again for the same offence, nor on the same facts for any other offence for which a different charge from the one made against him might have been convicted under Sub-section (1) of Section 221, or for which he might have been convicted under Sub-section (2) thereof.

This Section embodies the ancient maxim "nemo dabet vis vexari pro eadem causa" (no person should be twice disturbed for the same cause) and provides that where a person has once been tried and convicted or acquitted of an offence, he cannot again be tried for the same offence or for any offence which is not distinct from the one previously tried.

It incorporates the common law principle of the well known pleas of autrefois acquit (formerly acquitted) and autrefois convict (formerly convicted), namely, that no person shall be punished or put in peril or jeopardy twice for the same offence. The principle is incorporated in Article 20 of the Constitution. The principle does not rest on any doctrine of estoppel but on grounds of public policy.

In Assistant Custom's Collector v. L.R. Melwani AIR 1970 SC 962 Supreme Court held that in order to get the benefit of Section 300, it is necessary for an accused person to establish that he had been tried by court of competent jurisdiction, for an offence and he is convicted or acquitted of that offence and said conviction or acquittal is in force. If that much is established, then only the accused is not liable to be tried again for the same offence nor on same facts for any other offence, for which a different charge from the one made against him, might have been made or for which he might have been convicted.

In view of the above discussion it is clear that in case in hand, order of conviction passed by Magistrate is void and liable to be set aside.

Ans. Section 306 of Code of Criminal Procedure deals with procedure to be adopted by a Magistrate for tendering pardon to accomplice. Section 306 says :-

(1) With a view to obtaining the evidence of any person supposed to have been directly or indirectly concerned in or privy to an offence to which this section applies, the Chief Judicial Magistrate or a Metropolitan Magistrate at any stage of the investigation or inquiring into, or the trial of, the offence, and the Magistrate of the first class inquiry into or trying the offence, at any stage of the inquiry or trial, may tender a pardon to such person on condition of his making a full and true disclosure of the whole of the circumstances within his knowledge relative to the offence and to every other person concerned, whether as principal or abettor, in the commission thereof.

(2) This section applies to -

(a) any offence triable exclusively by the Court of Session or by the Court of a Special Judge appointed under the Criminal Law Amendment Act, 1952 (46 of 1952);

(b) any offence punishable with imprisonment which may extend to seven years or with a more severe sentence.

(3) Every Magistrate who tenders a pardon under Sub-section (1) shall record -

(a) his reasons for so doing;

(b) whether the tender was or was not accepted by the person to whom it was made,

and shall, on application made by the accused, furnish him with a copy of such record free of cost.

(4) Every person accepting a tender of pardon made under Sub-section (1) -

(a) shall be examined as a witness in the Court of the Magistrate taking cognizance of the offence and in the subsequent trial, if any;

(b) shall, unless he is already on bail, be detained in custody until the termination of the trial.

(5) Where a person has accepted a tender of pardon made under Sub-section (1) and has been examined under Sub-section (4), the Magistrate taking cognizance of the offence shall, without making any further inquiry in the case, -

(a) commit it for trial -

(i) to the Court of Session if the offence is triable exclusively by that Court or if the Magistrate taking cognizance is the Chief Judicial Magistrate;

(ii) to a Court of Special Judge appointed under the Criminal Law Amendment Act, 1952 (46 of 1952), if the offence is triable exclusively by that Court;

(b) in any other case, make over the case to the Chief Judicial Magistrate who shall try the case himself.

The object of this section is to allow pardon in cases where grave offence is allegedly committed by several persons, to one of the accused who is ready to give evidence of complicity of accused in the crime.

In State of U.P. v. K.N. Aggerwal, 1973 Cri.L.J. 1196 (SC), it was observed that Section 306 empowers a Chief Judicial Magistrate or a Metropolitan Magistrate or Magistrate of first class to tender pardon to a person who is supposed to have been directly or indirectly concerned in, or privy to, an offence under investigation or inquiry on the condition that he makes a full and true disclosure of all the circumstances within his knowledge in relation to the accused and to the offence."

Then Section 307 enables the court to tender a pardon at any time after the commitment of the case but before judgment is passed, with a view to obtaining at the trial the evidence of any evidence of any person supposed to have been directly or indirectly concerned or privy to any such offence, tender a pardon on the same conditions as provided under section 306 of lode to such person. Section 308 of Code says :

"(1) Where, in regard to a person who has accepted a tender of pardon made under section 306 or section 307, the Public Prosecutor certifies that in his opinion such person has, either by wilfully concealing anything essential or by giving false evidence, not complied with the condition on which the tender was made, such person may be tried for the offence in respect of which the pardon was so tendered or for any other offence of which he appears to have been guilty in connection with the same matter, and also for the offence of giving false evidence :

Provided that such person shall not be tried jointly with any of the other accused :

Provided further that such person shall not be tried for the offence of giving false evidence except with the sanction of the High Court, and nothing contained in Section 195 or Section 340 shall apply to that offence.

(2) Any statement made by such person accepting the tender of pardon and recorded by a Magistrate under section 164 or by a Court under Sub-section (4) of section 306 may be given in evidence against him at such trial.

(3) At such trial, the accused shall be entitled to plead that he has complied with the condition upon which such tender was made; in which case it shall be for the prosecution to prove that the condition has not been complied with.

(4) At such trial, the Court shall -

(a) if it is a Court of Session, before the charge is read out and explained to the accused;

(b) if it is the Court of a Magistrate, before the evidence of the witnesses for the prosecution is taken,

ask the accused whether he pleads that he has complied with the conditions on which the tender of pardon was made.

(5) If the accused does so plead, the Court shall record the plea and proceed with the trial and it shall, before passing judgment in the case, find whether or not the accused has complied with the conditions of the pardon, and, if it finds that he has so complied it shall, notwithstanding anything contained in this Code, pass judgment of acquittal.

In State v. Jagjit Singh, AIR 1989 SC 598 it was observed that Court has to consider before trying the approver for the original offence whether he has some act or omission on his part or failed to comply with the conditions of pardon, it is the duty of the prosecutor, to establish that approver has failed to comply with conditions of pardon either -

(a) by willfully concealing anything essential.

(b) by willfully giving false evidence State cannot withdraw the pardon from the approver nor approver can cast away the pardon granted to him till he is examined as a witness by prosecution.

Ans. Section 311 of Code Criminal procedure says "Any court may, at any stage of any inquiry, trial or other proceedings under this Code, summons any person as a witness or examine any person in attendance, throughout summoned as witness or re-call and re-examine any person already examined and the court shall summon and examine or recall and re-examine any such person if his evidence appears to it to he essential to the just decision of the case."

In Pritam Singh v. State, 2002(3) RCR (Cri.) 767, it was observed that Section 311 of Code has given ample power to allow documentary or oral evidence which is per se admissible and necessary for just decision of case.

Similarly in Satyadeen @ Ram Singh v. State (NCT of Delhi) 2003 [CIII] Delhi Law Times 135 Where offence was committed in 1989 and Charge-sheet was filled in 1991 and Prosecution Evidence and Statement of Accused under section 313 Cr.P.C., was already recorded and after giving opportunity to defence to lead evidence when case was at the stage of argument accused moved application under section 311 Cr.P.C. to cross-examine certain PWs. Delhi High Court observed that section 311 Cr.P.C. give wide discretion and mandate to Trial Court to allow additional evidence, court would not permit prosecution or Defence fo fill lacuna left in the case.

Ans. Section 321 of Code of Criminal Procedure deals with withdrawal from prosecution. Section 321 says:

"The Public Prosecutor or Assistant Public Prosecutor, incharge of the case may, with the consent of the court, at any time before the judgment is pronounced, withdraw from prosecution of any person either generally or in respect of any one or more of the offences for which he is tried.

So Section 321 of Code is an enabling provision and vests in the Public Prosecutor the discretion to apply to the court for its consent to withdraw from the prosecution of any person. Two main features of Section 321 are to be borne in mind i.e. Initiative is that of Public Prosecutor to apply for consent of court for withdrawal of prosecution, court then has to give consent. Judicial function implicit in the exercise of judicial discretion for granting the consent would mean that court has to satisfy itself that executive function of Public Prosecutor has not been improperly exercised.

Supreme Court recently in Abdul Karim v. State of Karnataka AIR 2001 SC 116 while discussing Section 321 Cr.P.C. and case law on the provision of law, has laid down following propositions:

(i) Application under Section 321 of Code must aver the Public Prosecutor is in good faith satisfied, on consideration of all relevant materials, that his withdrawal from prosecution is in Public Interest and it will not stifle or thwart the process or cause in justice.

(ii) Though Government may have ordered the Public Prosecutor to withdraw from Prosecution, it is for Public Prosecutor to apply his mind to all material and in good faith to be satisfied thereon that the Public Interest will be served by withdrawal.

(iii) The Court has to be satisfied after considering all materials that Public Prosecutor has applied his mind independently thereto and he acting in good faith and is of opinion that withdrawal from prosecution is in public interest.

(iv) It is not necessary for the court to assess the evidence to discover whether the case would end in conviction or acquittal, what court is to see, whether Public Prosecutor had applied his mind in good faith on all material of case and application is made in the interest of Public Interest and justice and not to thwart and stifle the process of law.

(v) Section 321 contemplates consent by court in a supervisory and to an adjudicatory manner. The court must ensure that Public Prosecutor had made application for withdrawal of prosecution after independent consideration and then exercise its discretion of giving consent or decline the consent.

Ans. Section 353 of Code of Criminal Procedure Code deals with the mode of delivering a judgement. Section 353 lays down that judgment of criminal court of original jurisdiction shall be pronounced in open court by Presiding Officer immediately after the termination of trial or at some subsequent date of which parties or their pleaders must have notice and it shall be pronounced:

(a) By delivering the whole of the judgment.

(b) By reading out the whole of the judgment.

(c) By reading out operative part of judgment and explaining the substance of it, in the language which is understood by accused or his pleader.

Presiding Officer shall sign every page of the judgment and it shall be date by him. Section 353 also provides that copy of judgement, if it is pronounced in the manner as provided in Clause (c), be immediately made available for the perusal of parties or their pleaders free of cost. Sub-section (5) says that if accused is in custody, he shall be brought to hear the judgment and Sub-section (6) to Section 353 says if Accused is not in custody, he shall be required to attend the court to hear the judgment unless his personal attendance has been dispensed with during the trial and sentence of fine is to be imposed or he is to be acquitted. Sub-section (7) also makes it clear that judgment of criminal court shall not be invalid by reason of absence of any party or his pleader on the day and from the place notified for the pronouncement of judgment or by reason of any defect in serving notice on parties

Section 354 of Code then provides for language and contents of judgement. It lays down that every judgment as referred to in Section 353 (a) shall be written in the language of court (b) shall contain points of determination and decision thereon and reasons for the decision (c) shall specify the offences of Indian Penal Code or of any other law of which accused is acquitted or convicted and if the accused is acquitted it must contain directions that he be set at liberty. Sub-section (2) to Section 354 says when it is doubtful under which of two Sections or two parts of same Section of law, the offence falls, the court shall distinctly express the same and pass the judgment in the alternative.

Section 354(3) then provides that when an accused is sentenced to death or with imprisonment for life or for any term, the judgment shall contain reasons for sentence awarded and in case of sentence of death, the special reasons for such sentence.

In State of Gujarat v. Mulchand, 1990 Criminal Law Journal 2399 It was observed that every judgment must contain points for decision, decision thereon and reasons for the decision. This provision is mandatory. Supreme Court recently in State of Karnataka v. Registrar General of High Court of Karnataka, AIR 2000 SC 2626 has observed that "Judicial decorum requires that judgements and Orders should confine to facts and legal points involved in particular cases which judges deal with. Judicial disposition is definitely different from a paper presented for seminar dissertation."

Ans. Section 357, Cr.P.C. provides Rules for compensation in four classes of cases namely:

i) Compensation for prosecution expenses

ii) Compensation to the victims

iii) Compensation to dependents specified in Fatal Accidents Act, 1855, i.e. every such action or suit shall be for the benefit of the wife, husband, parent and child if any, of the person whose death shall have been so caused and shall be brought by and in the name of the executor, administrator or representative of the person deceased.

iv) Compensation to victims from the amount of fine imposed.

a) When a Court imposed a sentence of which fine does not form a part, the Court may when passing judgment, order the accused person to pay, by way of compensation, such amount as may be specified in the order to the person who has suffered any loss or injury by reason of act for which the accused person has been so sentenced.

(b) An order under this Section may also be made by an Appellate Court or by the High Court or Court of Session when exercising its powers of revision.

(c) At the time of awarding compensation in any subsequent civil suit relating to the same matter, the Court shall take into account any sum paid or recovered as compensation under this Section .

Thus, for the first time Section 357(3), Cr.P.C. has not only recognised the philosophy of compensation simpliciter to the victims of crime even when no sentence of fine is imposed, but also added a new positive dimension to the idea of re-compensating them. Prior to inclusion of this clause no compensation could be awarded unless a substantive sentence of fine was passed and that too this was limited only to the extent of the fine actually realised. It can be for any amount and not limited to the amount of fine imposed or recovered.

From the above-mentioned clauses it is evident that Section 357 Cr.P.C. in essence, empowers a Court to award compensation to any person for any `loss' or `injury' caused by an offence in those cases where `fine' does or does not form part of the sentence imposed. But under Sub-section (1) of Section 357, it can do so only out of the `fine' imposed on, and recovered from, the offender if such compensation, in its opinion, is recoverable in a Civil Court. The amount so awarded under this Sub-section , obviously, cannot exceed that of the fine so imposed/recovered as the underlying idea in directing such compensation is to collect the fine and pay it to the person who has suffered the loss, while under Sub-section (3), a Court is empowered to order a specified amount of compensation irrespective of the fact that the offence is punishable with fine or not and/or fine is actually imposed or not.

Ans. Release on probation of good conduct or after admonition. The provisions for releasing the accused on probation are contained in Section 360. When any person not under twentyone years of age is convicted of an offence punishable with fine or with imprisonment for a term of seven years or less, or when any person under twentyone years of age or any woman is convicted of an offence not punishable with death or imprisonment for life, and no previous conviction is proved against the offender, if it appears to the court before which he is convicted, regard being had to age, character or antecedents of the offender, and to the circumstances under which the offences was committed, that it is expedient that the offender should be released on probation of good conduct, the court may, instead of sentencing him at once to any punishment, direct that he be released on his entering into a bond, with or without sureties, to appear and receive sentence when called upon during such period (not exceeding three years) as the court may direct and in the mean time to keep the peace and be good behaviour; provided that where any first offender is convicted by a Magistrate of the second class not specially empowered by the High Court, and the Magistrate is of opinion that the powers conferred by this Section should be exercised, he shall record his opinion to that effect, and submit to a Magistrate of the first class, forwarding the accused to, or taking bail for his appearance before, such Magistrate, who shall dispose of the case in the manner provided by Sub-section (2) of Section 360 of the Code of Criminal Procedure.

In Ved Parkash v. State of Haryana 1981 Criminal Law Journal 161 (SC), it was observed that sentencing an accused person is a sensitive exercise of discretion and not a routine or mechanical prescription acting on hunch. The trial court should collect materials necessary to help award a just punishment in the circumstances. In order to attract the provisions of Section 360 nature of offence, the circumstances in which it is committed, the age, character and antecedents of the offender must be taken into account and it is only after considering all these factors, the court considers it to be expedient action under this Section should be taken. Even if Section 360 is not attracted it is the duty of the Court to be activist enough to collect such facts as have a bearing on punishment with a rehabilitating slant.

Special reasons to be recorded. It is laid down in Section 361 that where in any case the court could have dealt with,

(a) an accused person under Section 360 or under the provisions of the Probation of Offenders Act, 1958, or

(b) a youthful offender under the Children Act, 1960, or any other law for the time being in force for the treatment, training or rehabilitation of youthful offenders,

but has not done so, it shall record in its judgment the special reasons for not having done so.

Then Sub-section (3) of Section 360 of Code says : In any case in which a person is convicted of theft, theft in a building, dishonest misappropriation, cheating or any offence under the Indian Penal Code (45 of 1860), punishable with not more than two years' imprisonment or any offence punishable with fine only and no previous conviction is proved against him, the Court before which he is so convicted may, if it thinks fit, having regard to the age, character, antecedents or physical or mental condition of the offender and to the trivial nature of the offence or any extenuating circumstances under which the offence was committed, instead of sentencing him to any punishment, release him after due admonition.

Ans. Section 372 of Criminal Procedure Code says that `No appeal lies from any judgment or order of criminal court except as provided for, by this code or by any other law for the time being in force." So right of appeal is not a natural or inherent right. Right of appeal must be expressly provided by statute. Right of appeal is not a mere matter of procedure but is a vested right.

Section 374 of Code provides for forum of appeal in following case.

(i) In case of conviction on trial held by High Court in its extraordinary criminal jurisdiction may lie to Supreme Court.

(ii) Appeal against order of conviction by Session Judge or a Court awarding sentence of imprisonment for more than seven years, shall lie to High Court.

(iii) Appeals to Session Court against

(a) Order of conviction by Metropolitan Magistrate or Assistant Session Judge or Magistrate of the First Class or the Second Class

(b) Sentence passed by the Chief Judicial Magistrate on a reference being made to him under Section 325 or

(c) Order or sentence passed by any Magistrate under Section 360.

Then Section 375 says no appeal lies against the Order of conviction when an accused pleads guilty and has been convicted on such plea if (a) Conviction is by High Court or (b) Conviction is by court of Session, Metropolitan Magistrate or Magistrate of the First or Second Class, except as to the extent or legality of the sentence.

Then Section 376 provides that no appeal lies where High Court passes only sentence of imprisonment for term not exceeding, 6 months or fine upto Rs. 1000 or where Sessions Court or Metropolitan Magistrate pass sentence of imprisonment upto 3 months or fine upto Rs. 200 or both or where First Class Magistrate passes sentence of fine upto Rs. 100.

Section 377 of Code then provides that Central Government in cases investigated by Delhi Special Police Establishment or by Central Agency or State Government in any other cases, on trial held by any court other than High Court, direct the public prosecutor to present an appeal against conviction on the ground of inadequacy. High Court shall not enhance the sentence except after giving an accused reasonable opportunity of showing cause against such enhancement.

Section 378 provide that State or Central Government may direct Public Prosecutor to present appeal to the High Court from an original or appellate Order of acquittal by any courts subordinate to it.

Revision. Section 397 of Criminal Procedure Code empower the High Court and the Session Judge to call for records of any inferior criminal court and examine them for the purpose of satisfying themselves as to whether sentence, finding or order of such inferior court is legal, correct.

In Munna Devi v. State of Rajasthan AIR 2002 SC 107, it was observed that Revisional Powers can be exercised only when it is shown that there is a legal bar against the continuance of criminal proceedings or framing of charge or facts as stated in FIR, even if taken at the face value and accepted in their entiretly, do not constitute the offence for which accused has been charged. Revisional Court can not appreciate the facts in the manner as Trial Court or appellate courts are expected to do.

Section 397(1) confer concurrent jurisdiction to High Court and Court of Session in the matter of revision. Section 397(2) however makes it clear that Revisional Jurisdiction shall not be exercised in respect of interlocutory orders.

Ans. Sections 395 and 396 of Code of Criminal Procedure provide as to when Reference can be made High Court and Sections 397 to 405 provide for revision.

Reference : Section 395(1) of Code lays down that "If any court is satisfied that in a case pending before it, involves a question as to validity of any Act, Regulation or Ordinance or of any provision contained in an Act, Ordinance, Regulation the determination of which is necessary for the disposal of the case and which in the opinion of such court is invalid or inoperative and has not been so declared by High Court, to which, such court is subordinate or by Supreme Court, the court shall state the case setting out its opinion and reason therefore and refer the same for the decision of High Court. Sub-section (2) of Section 395 empower the Session Judge or Metropolitan Magistrate to refer for the opinion, any question of law that has arisen in course of hearing of a case pending before such Judge or Magistrate to High Court, when Sub-section (1) do not apply.

Then Section 396 says upon such reference, the High Court shall pass such order thereon as it think fit and shall cause a copy of such order to be sent to the court by which the reference was made, which shall dispose of the case conformally to the said order.

REVISION According to Section 397, the High Court or any Session Judge may call for and examine the record of any proceeding before an inferior criminal court for the purpose of satisfying itself or himself as to correctness, legality or propriety or any finding, sentence or order recorded or passed and as to the regularity of any proceedings of such inferior court, when calling for the record direct the execution of the sentence or order be suspended and if the accused is in confinement that he be released on bail or on his own bond pending the examination of the record.

Sub-section (2) to Section 397 says the powers of revision conferred by Sub-section (1) shall not be exercised in relation to any "interlocutory order" passed in any appeal, inquiry, trial or other proceeding.

In V.C. Shukla v. State through C.B.I. AIR 1980 SC 962 Supreme Court observed that the words `interlocutory order used in Section 397(2) relates to various stages of the trial, namely appeal, inquiry, trial etc. The object seems to be to cut down the delays in stages throughout which a criminal case passes before it culminates in an acquittal, discharge or conviction... the expression `interlocutory order' has to be given a liberal construction in favour of the accused in order to ensure fairness of the trial... Any order which substantially affects the rights of the accused or decides certain rights of the parties cannot be said to be an interlocutory order so as to bar the revision against order. The revisional power of High Court and Session Judge could be attracted if the order was not purely interlocutory but intermediate or quasi final."

Following are thus points of distinction between Reference and Revision:

(i) Reference is permissible when in a pending case, a substantial question as to validity of any Act; Ordinance or Regulation or of any provision arose. Revision lies only on the question of correctness, legality or propriety of any finding, sentence or order or as to regularity of any proceeding.

(ii) Reference can be made in a pending case whereas Revision lies both in pending and decided cases

(iii) Reference can be made to the High Court but Revision can be filed before High Court or Session's Court.

COMPOUNDABLE AND NON-COMPOUNDABLE CASES Law makes a difference between various classes of offences and allows compromise in some kind of offences and no compromise in other. Offences in which compromise can be affected are known as compoundable offences and those offences in which compromise can not be effected are non-compoundable.

Principle of English law is that composition of an offence is illegal if the offence is one of public concern but lawful if offence is of private nature and for which damages may be recovered in civil action.

Section 320(1) of Code of Criminal Procedure specifies certain offences which can be compounded by persons mentioned in the table annexed thereto. In such cases there is no necessity to obtain permission of Court before compounding such offences. Section 320(2) of Code lays down certain offences which can be compounded only with the permission of Court. Section 320 specifically says no offence shall be compounded except those provided in this Section .

So only distinction is that offences which are mentioned in Sub-sections (1) and (2) of Section 320 of Code are compoundable and those which are not mentioned are non-compoundable. Offence lawfully compounded shall have the effect of acquittal.

Ans. Whenever it is made to appear to the Supreme Court that an order under section 406 of the Code of Criminal Procedure is expedient for the ends of justice, it may direct that any particular case or appeal be transferred from one High Court to another High Court or from a Criminal Court subordinate to one High Court to another Criminal Court of equal or superior jurisdiction subordinate to another High Court.

The Supreme Court may act under section 406, Criminal Procedure Code, only on the application of the Attorney-General of India or the Advocate-General of the State, and supported by affidavit or affirmation.

Where any application for the exercise of the powers conferred by this section is dismissed, the Supreme Court may if it is of opinion that the application was frivolous or vexatious, order the applicant to pay by way of compensation to any person, who has opposed the application, such sum not exceeding one thousand rupees as it may consider appropriate in the circumstances of the case.

Assurance of a fair trial is the first imperative of the dispensation of justice and the central and crucial criterion for the court to consider when a motion for transfer is made; the hypersensitivity or relative convenience of a party or easy availability of legal services or like mini-grievances are irrelevant. Something more substantial, more compelling, more unperilling, from the point of view of public justice and its attendant, environment, is necessitious if the Court is to exercise its power of transfer.

Ans. Section 406 of Cri. P.C. provides -

"(1) Whenever it is made to appear to the High Court -

(a) that a fair and impartial inquiry or trial cannot be had in any Criminal Court subordinate thereto; or

(b) that some question of law of unusual difficulty is likely to arise; or

(c) that an order under this section is required by any provision of this Code, or will tend to the general convenience of the parties or witnesses, or is expedient for the ends of justice,

it may order -

(i) that any offence be inquired into or tried by any Court not qualified under Sections 177 to 185 (both inclusive), but in other respects competent to inquire into or try such offence;

(ii) that any particular case or appeal, or class of cases or appeals, be transferred from a Criminal Court subordinate to its authority to any other such Criminal Court of equal or superior jurisdiction;.

(iii) that any particular case be committed for trial to a Court of Session; or

(iv) that any particular case or appeal be transferred to and tried before itself.

(2) The High Court may act either on the report of the lower Court, or on the application of a party interested, or on its own initiative:

Provided that no application shall lie to the High Court for transferring a case from one Criminal Court to another Criminal Court in the same sessions division, unless an application for such transfer has been made to the Sessions Judge and rejected by him.

(3) Every application for an order under sub-section (1) shall be made by motion, which shall, except when the applicant is the Advocate-General of the State, be supported by affidavit or affirmation.

(4) When such application is made by an accused person, the High Court may direct him to execute a bond, with or without sureties, for the payment of any compensation which the High Court may award under sub-section (7).

(5) Every accused person making such application shall give to the Public Prosecutor notice in writing of the application, together with a copy of the grounds on which it is made; and no order shall be made on the merits of the application unless at least twenty-four hours have elapsed between the giving of such notice and the hearing of the application.

(6) Where the application is for the transfer of a case or appeal from any subordinate Court, the High Court may, if it is satisfied that it is necessary so to do in the interests of justice, order that, pending the disposal of the application, the proceedings in the subordinate Court shall be stayed, on such terms as the High Court may think fit to impose:

Provided that such stay shall not affect the subordinate Court's power of remand under Section 309.

(7) Where an application for an order under sub-section (1) is dismissed, the High Court may, if it is of opinion that the application was frivolous or vexatious, order the applicant to pay by way of compensation to any person who has opposed the application, such sum not exceeding one thousand rupees as it may consider proper in the circumstances of the case.

(8) When the High Court orders under sub-section (1) that a case be transferred from any Court for trial before itself, it shall observe in such trial the same procedure which that Court would have observed if the case had not been so transferred.

(9) Nothing in this section shall be deemed to affect any order of Government under Section 197."

So, the High Court can order a transfer under this section on any of the following grounds :-

(1) Fair and impartial inquiry or trial not being possible.

(2) Likelilhood of unusual difficulty on a question of law arising in the case.

(3) Requirement of the transfer under any provision of this Code.

(4) General convenience of the parties or witnesses.

(5) Expediency for the ends of justice.

Ans. Section 408 Cri. P.C. says that whenever it is made to appear to Session Judge that is expident for the ends of justice, he may order that any particular case be transfer from one criminal court to another criminal court in his session division. Session Judge may pass such order either on the report of lower court or on the application of party interested or on his own initiative.

The provision of sub-sections (3), (4), (5), (6), (7) and (9) of section 407 of Code will apply in relation to any application made to Session Judge for an order under sub-section 1 of section 408.

Section 409 of Code of Criminal Procedure empowers the Session Judge to withdraw any case or appeal which he has made over to any Assistant Session Judge or Chief Judicial Magistrate subordinate to him. Sub-section (2) provides that a Session Judge can recall any case or appeal which he has made over to any Additional Session Judge, however he can do so at any time before the trial the case or the hearing of the appeal has commenced.

Where the Session Judge withdraws or recalls a case or appeal under sub- section (1) or (2) of Section 409 of the Code, he may either try the case in his own court or hear the appeal himself or make it over in accordance with the provisions of the Code to another court for the trial or hearing as the case may be.

Ans. To suspend or remit sentences. - Section 432 empowers the State Government to suspend the execution of the sentence or remit the whole or any part of the punishment to which any person has been sentenced. The appropriate Government may, at any time, without conditions or upon any conditions which the person sentence accepts, suspend the execution of his sentence or remit the whole or any party of the punishment to which he has been sentenced.

When an application is made to the appropriate Government for the suspension or remission of a sentence, the appropriate Government may require the Presiding Judge of the Court before or by which the conviction was held or confirmed to state his opinion as to whether the application should be granted or refused, together with his reasons for such opinion and also to forward with the statement of such opinion a certified copy of the record of the trial or of such record thereof as exists.

If any condition on which a sentence has been suspended or remitted is, in the opinion of the appropriate Government, not fulfilled, the appropriate Government may cancel the suspension or remission, and thereupon the person in whose favour the sentence has been suspended or remitted may, if at large, be arrested by the police officer, without warrant and remanded to undergo the unexpired portion of the sentence.

The condition on which a sentence is suspended or remitted under this section may be one to be fulfilled by the person in whose favour the sentence is suspended or remitted, or one, independent of his will.

The appropriate Government may, by general rules or special orders give directions as to the suspension of sentence and the conditions on which petitions should be presented and dealt with. Provided that in the case of any sentence (other than a sentence of fine) passed on a male person above the age of eighteen years, no such petition by the person sentenced or by any other person on his behalf shall be entertained, unless the person sentenced is in jail and -

(a) where such petition is made by the person sentenced, it is presented through the officer-in-charge of the jail;

In State of Haryana and others v. Mahinder Singh etc., 2001(1) RCR(Criminal) 627 (SC) is was observed : "Prisoners have no absolute right for remission of their sentence unless except what is prescribed by law and the circular issued thereunder. That special remission shall not apply to a prisoner convicted of a particular offence can certainly be a relevant consideration for the State Government not to exercise power of remission in that case."

To commute sentence. - According to Section 433, the appropriate Government may without the consent of the person sentenced, commute -

(a) a sentence of death, for any other punishment provided by the Indian Penal Code, 1860;

(b) a sentence of imprisonment for life or imprisonment for a term not exceeding fourteen years or for fine;

(c) a sentence of rigorous imprisonment fo simple imprisonment for, any term to which that person might have been sentenced, or for fine;

(d) a sentence of simple imprisonment, for fine.

Restrictions on Powers - Section 433(A) of Code provides that notwithstanding any thing contained in section 432, where a sentence of imprisonment whole life imposed on conviction of a person for an offence for which death is one of the punishments provided by law, or where a sentence of death imposed on a person has been commuted under section 433 into one of imprisonment for life, such person shall not be released from prison unless he had served at least fourteen years of imprisonment.

In State of Punjab v. Kesar Singh, 1997(1) RCR(Criminal) 14 (SC) it was observed that the mandate of section 433 Cr. P.C. enables the Government in an appropriate case to commute the sentence of a convict and to prematurely order his release before expiry of the sentence as imposed by the Court. Clause (b) of Section 433, Cr. P.C. provides that the sentence of imprisonment for life may be commuted for imprisonment for a term not exceeding 14 years or fine.

In Union Territory of Chandigarh v. Charanjit Kaur, 1996(2) RCR(Criminal) 183 (SC) it was observed that Section 433 of Code, empowers the Government in appropriate case, without the consent of the person sentenced, to commute the sentence and to prematurely released the convict however clause (b) of the section mandates that 14 years is the minimum sentence required to be served by the convict for taking benefit under this section.

In case of the death sentence, Concurrent power of Central Government. - Section 434 provides that the powers conferred by sections 432 and 433 of the Code of Criminal Procedure upon the State Government may in the case of sentence of death also be exercised by the Central Government.

In certain case to consult Central Government. - It is provided by Se. 435 that the powers coffered by sections 432 and 433 of the code of Criminal Procedure upon the State Government to remit or commute a sentence, in any case where the sentence is for an offence -

(a) which was investigated by the Delhi Special Police Establishment constituted under the Delhi Special Police Establishment Act, 1946 or by any agency empowered to make investigation into an offence under any Central Act other than the Code of Criminal Procedure, or

(b) which involved the misappropriation or destruction of, or damage to, any property belonging to the Central Government, or

(c) which was committed by a person in the service of the Central Government while acting or purporting to act in the discharge of his official duty,

shall not be exercised by the State Government except after consultation with the Central Government.

No order of suspension, remission or commutation of sentences passed by the State Government in relation to a person, who has been convicted of offences, some of which relate to a matter to which the executive power of the Union extends, and who has been sentenced to separate terms of imprisonment which are to run concurrently, shall gave effect unless an order for the suspension, remission or commutation, as the case may be, of such sentences has also been made by the Central Government in relation to the offences committed for such person with regard to the matters to which the executive powers of the Union extends.

Ans. Chapter XXXIII of Code of Criminal Procedure deals with provisions as to Bail and Bonds

Section 436 of Code provides as to bail in bailable offences Section 436 says when any person is arrested or detained in bailable offence or appears before the court, then such person shall be released on bail on his executing the bail bond. Provisions of Section 436 are mandatory and the court or officer-in-charge of Police Station as the case may be is bound to release the accused in bailable offence on bail provided he is prepared to give it.

Then Section 437 of Code provides as to bail by Magistrate in Non-bailable offences. Section 437(1) says when any person accused of or suspected of the commission of any non-bailable offence is arrested or detained without warrant by officer-in-charge of a police station or appears or is brought before court other than the High Court or Court of Session, he may be released on bail, but

(i) Such person shall not be so released if there appear reasonable grounds for believing that he has been guilty of an offence punishable with death or imprisonment for life.

(ii) Such person shall not be so released if such offence is a cognizable offence and he had been previously convicted of an offence punishable with death or imprisonment for life or imprisonment for seven years or more or he had been previously convicted on two or more occasions of a non-bailable and cognizable offence.

Provided that court may direct that a person referred to in Clause (i) or (ii) be released on bail if such person is under the age of sixteen years or is a woman or is sick or infirm.

In Venkataramanappa v. State of Karnataka 1992 Criminal Law Journal 2268, it was observed that Section 437 of Code gives a discretionary power to Court (other than the High Court or Court of Session) to release an accused of non-bailable offence, on bail, unless, there appear reasonable grounds that the accused has been guilty of an offence punishable with death or with imprisonment for life. But (1) a person under the age of sixteen years (2) a woman or (3) a sick or infirm person may be released on bail even if the offence charged is punishable with death or imprisonment for life.

Section 438 of Code then provides as to Anticipatory Bail and Section 439 provides power to grant bail by High Court and Session Court. Section 439(1) lays down that High Court or Court of Session may direct:

(a) that any person accused of an offence and in custody, be released on bail and if the offence is of the nature specified in Sub-section (3) of Section 437, may impose any condition which it considers necessary.

(b) that any condition imposed by a Magistrate when releasing any person on bail be set aside or modified.

Proviso to Section 439 then says in case of offences exclusively triable by court of session or which are punishable with death or imprisonment for life notice of Bail application shall be given to Public Prosecutor before granting bail.

Sub-section (2) to Section 439 provide for cancellation of bail.

In State of Rajasthan v. Bal Chand AIR 1977 SC 2447 Supreme Court discussed principles of bail and it was observed that generally it is the Rule to allow bail rather than to refuse bail and bail ought not to be withheld as punishment. Since the law presumes an accused as innocent till his guilt is proved, he must be allowed opportunity to look after his own case unless the circumstances are such that he should not be released on bail. The principles to guide the courts are the probability of the accused appearing to take his trial and not his supposed guilt or innocence. There is no hard and fast Rule as to when bail should be granted in non-bailable cases and though the discretion is unfettered, it must be exercised judicially. Considerations which are to be weighed in granting or refusing bail are:

(a) nature of the offence and its seriousness (b) character of evidence on which prosecution relies (c) Reasonable possibility of the accused person's abscondance (d) Reasonable possibility of accused person's tampering with prosecution evidence (f) Larger Interest of the Public and State etc.

Recently Supreme Court in Prahlad Singh Bhati v. N.C.T. (Delhi), 2001(2) RCR(Crl.) 377 has held that there is no bar for magistrate to consider bail application of accused of offence exclusively triable by court of session however it would be proper and appropriate that in such cases the magistrate directs the accused person to approach the court of session for the purpose of getting relief of bail.

Ans. Provisions for grant of anticipatory bail are given in Section 438 of Code of Criminal Procedure. Section 438(1) says "When any person has reason to believe that he may be arrested on an accusation of having committed non-bailable offence, he may apply to the High Court or Court of Session for direction under this Section and that court may, if it thinks fit, direct that in the event of such arrest, he shall be released on bail."

Sub-section (2) to Section 438 further provides that when the court makes such directions it may include such conditions it considers fit including those specified in clauses (i) to (iv) of Sub-section (2)."

MEANING : Anticipatory bail means bail in anticipation of Arrest. `Arrest' consists of the actual seizure or touching of person's body with a view to his detention. The provision of Section 438 has been introduced by legislature purposely to give relief to one who believes that he has been falsely involved in a non-bailable offence and if timely approach is not made to court then he is likely to be humiliated.

Section 438 enables the courts (High Court or Court of Session) to grant anticipatory bail which means that if he is arrested bail shall be granted to him or if warrant is issued for his arrest, the warrant shall be bailable. In order that investigation may not be hampered Sub-section (2) provides that while granting anticipatory bail, the court may impose any condition as it deem fit including those specified in Sub- section (2).

The Law Commission in its 41st Report has observed :-

"The necessity for granting anticipatory bail arises mainly because sometimes influential persons try to implicate their rivals in false cases for the purpose of disgracing them or for getting them detained in jail. In recent times with the accentuation of political rivalry, this tendency is showing signs of steady increase. That apart where there are reasonable grounds for holding that a person accused of an offence is not likely to abscond or otherwise misuse his liberty while on bail, there seems no justification to require him first to submit to custody, remain in prison for some days and then apply for bail."

The Supreme Court while discussing the provision of anticipatory bail, has laid following proposition, in Gurbaksh Singh Sibbia v. State of Punjab AIR 1980 SC 1632 :

(i) Any person approaching the court of Session or the High Court is neither arrested person or detained person, Section 438(1) of Code lays down a condition which has to be satisfied before anticipatory bail can be granted. The applicant must show that he has reason to believe that he may be arrested for a non-bailable offence. Belief that the applicant may be arrested must be founded on reasonable grounds. Mere fear is not belief. The grounds on which the belief of applicant is based must be capable of being examined by the court objectively.

(ii) It can not be laid down that anticipatory bail can not be granted in respect of offences the punishment provided therefor is imprisonment for life, though court is free to refuse anticipatory bail in any case if there is material before it justifying such refusal.

(iii) High Court or Court of Session to whom the application for anticipatory bail is made ought to be left free in the exercise of their judicial discretion to grant bail if they think fit so to do on the particular facts and circumstances of case so warrant, on considerations similar to those mentioned in Section 437.

In Satbir Kataria v. State of Haryana 1995(3) Recent Criminal Reports 479 Punjab and Haryana High Court has observed "While granting anticipatory bail, court has to keep in mind nature and seriousness of offence, context of events likely to lead to making of charges, a reasonable possibility of accused's presence not being secured at the trial, a reasonable apprehension that witness will tampered with and larger interest of public and state.

Ans. Section 460 Cr.P.C. says about irregularities which do not vitiate proceedings. Section 460 reads as under - "If any Magistrate not empowered by law to do any of the following things, namely, -

(a) to issue a search-warrant under Section 94;

(b) to order, under Section 155, the police to investigate an offence;

(c) to hold an inquest under Section 176;

(d) to issue process under Section 187, for the apprehension of a person within his local jurisdiction who has committed an offence outside the limits of such jurisdiction;

(e) to take cognizance of an offence under clause (a) or clause (b) of Sub-section (1) of Section 190;

(f) to make over a case under Sub-section (2) of Section 192;

(g) to tender a pardon under Section 306;

(h) to recall a case and try it himself under Section 410; or

(i) to sell property under Section 458 or Section 459,

erroneously in good faith does that thing, his proceedings shall not be set aside merely on the ground of his not being so empowered."

And then Section 461 provides regarding irregularities which vitiate the proceedings. Section 461 reads as under - "If any Magistrate, not being empowered by law in this behalf, does not of the following things, namely -

(a) attaches and sells property under Section 83;

(b) issues a search-warrant for a document, parcel or other thing in the custody of a postal or telegraph authority;

(c) demands security to keep the peace;

(d) demands security for good behaviour;

(e) discharges a person lawfully bound to be of good behaviour;

(f) cancels a bond to keep the peace;

(g) makes an order for maintenance;

(h) makes an order under Section 133 as to a local nuisance;

(i) prohibits, under Section 143, the repetition or continuance of a public nuisance;

(j) makes an order under Part C or Part D of Chapter X;

(k) takes cognizance of an offence under clause (c) of Sub-section (1) of Section 190;

(l) tries an offender;

(m) tries an offender summarily;

(n) passes a sentence, under Section 325, on proceedings recorded by another Magistrate;

(o) decides an appeal;

(p) calls, under Section 397, for proceedings; or

(q) revises an order passed under Section 446,

his proceedings shall be void."

Ans. Section 465 lays down that subject to the provisions hereinbefore contained, no finding, sentence or order passed by a court of competent jurisdiction shall be reversed or altered by a court of appeal, confirmation or revision on account of any error, omission or irregularity in the complaint, summons, warrant, proclamation, order, judgment or other proceedings before or during trial or in any inquiry or other proceedings under the Code of Criminal Procedure, or any error, or irregularity in any sanction for the prosecution, unless in the opinion of that court a failure of justice has in fact been occasioned thereby.

In determining whether any error, omission or irregularity in any proceeding under the Code of Criminal Procedure, or any error, or irregularity in any sanction for the prosecution has occasioned a failure of justice, the court shall have regard to the fact whether the objection could and should have been raised at an earlier stage in the proceedings.

In A. Devindran v. State of T.N., AIR 1998 SC 2821, it was observed : "The sole object of Section 465 is to secure justice by preventing the invalidation of a trial already held, on the ground of technical breaches of any provision in the Code causing no prejudice to the accused. But by no stretch of imagination the aforesaid provisions can be attracted to a situation where a Court having no jurisdiction under the code does something or passes an order in contravention of the mandatory provisions of the Code. In view of the interpretation that after a criminal proceeding is committed to a Court of Session it is only the Court of Session which has the jurisdiction to tender pardon to an accused and the Chief Judicial Magistrate can be accepted and the evidence of the approver thereafter can be considered by attracting the provisions of Section 465 of the Code. The aforesaid provision cannot be applied to a patent defect of jurisdiction.

Ans. Bar to taking cognizance after lapse of the period of limitation. - It is provided in Section 468 that no court shall take cognizance of an offence after the expiry of the period of limitation except otherwise provided in the Code. The period of limitation shall be --

(i) six months if the offence is punishable with fine only ;

(ii) one year, if the offence is punishable with imprisonment for a term not exceeding one year ;

(iii) three years, if the offence is punishable with imprisonment for a term exceeding one year but not exceeding three years.

For the purposes of this section the period of limitation, in relation to offences which may be tried together, shall be determined with reference to the offence which is punishable with the more severe punishment or, as the case may be, the more severe punishment.

According to Section 469, the period of limitation, in relation to an offender, shall commence --

(i) on the date of the offence; or

(ii) where the commission of the offence was not known to the person aggrieved by the offence or to any police officer, the first day on which such offence comes to the knowledge of such person or to any police officer, whichever is earlier, or

(iii) where it is not known by whom the offence was committed, the first day on which the identity of the offender is known to the person aggrieved by the offence or to the police officer making investigation into the offence, whichever is earlier. In computing the said period, the day from which such period is to be computed shall be excluded.

Then Section 470 of the Code excludes the time in certain cases. Section 471 says that were the period of limitation expires on a day when the Court is closed the court may take cognizance on the day on which it re-opens. Then Section 472 says that in the case of a continuing offence, a fresh period of a limitation shall begin to run at every moment of time during which the offence continues. Then Section 473 says that not withstanding anything contained in above said provisions court may take cognizance of an offence even after the expiry of period of limitation.

In State of Punjab v. Sarwan Singh, AIR 1981 SC 1054, it was observed that object of Criminal Procedure Code in putting a bar of limitation on prosecution was clearly to prevent the parties from filing cases after long time, as a result of which material evidence may disappear and also to prevent abuse of process of court by filing vexatious and belated prosecutions after long time. The object which the statute seek to such serve is clearly in consonance with the concept of fairness of trial as enshrined in Article 21 of Constitution. It is therefore, of utmost importance that any prosecution whether by State or private complainant must abide by letter of law or take the risk of prosecution failing on the ground of limitation.

In V. Radha Mandhari v. V. Venkata Reddy, 1993 SCC (Cri.) 571, it was observed the provision of Section 468 and Section 473 of the Cr.P.C. cannot be treated as provisions parallel to the periods of limitation provided in the Limitation Act and the requirement of satisfying the Court that there was sufficient cause for condonation of delay under section 5 of that Act. There is a basic difference between Section 5 of the Limitation Act and Section 473 of the Code. For exercise of power under Section 5 of the Limitation Act, the onus is on the appellant or the applicant to satisfy the Court that there was sufficient cause for condonation of delay whereas Section 473 enjoins a duty on the Court to examine not only whether such delay has been explained but as to whether it is the requirement of the justice to condone or ignore such delay. As such, whenever the bar of Section 468 is applicable, the Court has to apply its mind on the question, whether it is necessary to condone such delay in the interest of justice. While examining the question as to whether it is necessary to condone the delay in the interest of justice the Court has to take note of the nature of offence, the class to which the victim belongs, including the background of the victim.