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VINUBHAI RANCHHODBHAI PATEL vs. RAJIVBHAI DUDABHAI PATEL & OTHERS

SCR Citation: [2018] 6 S.C.R. 1050
Year/Volume: 2018/ Volume 6
Date of Judgment: 16 May 2018
Petitioner: VINUBHAI RANCHHODBHAI PATEL
Disposal Nature: Appeals Disposed Off
Neutral Citation: 2018 INSC 521
Judgment Delivered by: Hon'ble Mr. Justice Jasti Chelameswar
Respondent: RAJIVBHAI DUDABHAI PATEL & OTHERS
Case Type: CRIMINAL APPEAL /1525/2009
Order/Judgment: Judgment
1. Headnote

Code of Criminal Procedure, 1973 – Chapter XVII – ss.211,212 and 213 – Defective framing of charges – Acquittal of accusedpersons – Interference with, if permissible – Three persons diedand five persons were injured allegedly in an attack by 17 persons– Sessions Court convicted 4 accused, while remaining 13 accusedpersons were acquitted – State appeals against acquittal of variousaccused, dismissed by High Court – On appeal, held: In the caseon hand where three persons died, the charge u/s.302 should havebeen framed against specifically named accused with respect toeach of the deceased – However, no clear charges were framed –Accused are entitled in law to know what is the charge on whichthey are put to trial – Further, since the prosecution invoked s.149,charges should have been framed specifying which of the accusedwere sought to be punished for which offence with the aid ofs.149,IPC – Sessions Court did not record clear findings as to theexistence of an unlawful assembly – Nor was there any clear findingregarding the common object of the assembly – High Court failedto take note of such defects in framing of charges – However, itwould not be justified to reverse the acquittal of accused personsin the case on hand inter alia on the grounds that the framing ofcharges is erroneous – Normally, consequence thereof should be afresh trial, but such a course of action after a lapse of 26 years ofthe occurrence of the crime would not serve any useful purpose assome of the accused died in the interregnum – Victims of the crimein this case are required to be compensated by the award of publiclaw damages – Families of each of the deceased be paid by theState an amount of Rs. 25,00,000/- each and the injured witnesses,if still surviving, otherwise their families be paid Rs.10,00,000/-each – Penal Code, 1860 – ss.302, 149, 141, 143, 146-148, 307,323 and 326 – Bombay Police Act – s.135 – Constitution of India –Art.21 – Evidence Act, 1872 – s.33 - Doctrine of vicarious liability.

2. Case referred
3. Act
  • Code Of Criminal Procedure, 1973 (2 of 1974)
  • Bombay Police Act, 1951 (22 of 1951)
  • Indian Evidence Act, 1872 (1 of 1872)
  • Constitution Of India
4. Keyword
  • Code of Criminal Procedure
  • 1973 – Chapter XVII – ss.211
  • 212 and 213
5. Equivalent citation
    Citation(s) 2018 AIR 2472 = 2018 (7) SCC 743 = 2018 (7) Suppl. SCC 743 = 2018 (7) JT 78 = 2018 (7) Suppl. JT 78 = 2018 (7) SCALE 474