Home > Recent Judgements > The Defense Cannot Challenge Prosecution Documents They Have Already Accepted As Genuine: Supreme Court
Oct 22, 2024
BACKGROUND
In the case of Shyam Narayan Ram vs. State of Uttar Pradesh & Anr., the Supreme Court addressed the application of Section 294 of the Code of Criminal Procedure (“CrPC”), which allows parties in a criminal trial to admit the genuineness of a piece of evidence, thereby dispensing the need for formal proof. The matter arose when the High Court sent the matter back to the trial court for fresh consideration of the PW2 (evidence) by the defense on the basis that the accused did not get a fair trial. The appellant contested this decision before the Supreme Court, arguing that such a remittal goes against Section 294 of the CrPC.
ISSUES
- Whether the defense, after admitting the genuineness of the prosecution’s documents under Section 294 of the CrPC, later challenges or discredits those documents?
- Whether the High Court can remit the case back to the trial court for reconsideration and re-examination despite the submission of those documents based on Section 294 of the CrPC?
JUDGEMENT
The Supreme Court set aside the High Court order and observed that when the defense admitted the genuineness of the prosecution documents and dispensed with its formal proof, then it would not be open for the courts to give another chance to the defense to discredit the documents that support the prosecution’s story.
Further, the court held that there was no error in the judgment of the trial court and considering the facts of the case where the defense repeatedly continued to admit the genuineness of the prosecution documents. Therefore, the High Court made an error in remitting the case back to the trial court.
OBSERVATION
The appeal was allowed by the Supreme Court, and the matter was remitted to the High Court for fresh consideration based on material on record. The Court also observed that once the defense admits the prosecution’s documents as evidence, they later cannot from the around and discredit them. Allowing such a reversal would defeat the purpose of Section 294 of the CrPC.
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