Summary punishment for perjury under CrPC applies only after deliberate falsity, justice-based necessity, and a fair show-cause opportunity.

Section 344 CrPC permits a court to summarily punish perjury only if, at the time of delivering judgment or final order, it forms an opinion that the witness intentionally gave false evidence or fabricated evidence, considers summary punishment necessary in the interests of justice, and gives a reasonable opportunity to show cause. The provision operates as an alternative summary mechanism for dealing with perjury and does not curtail the court's power under Section 340(1) where appropriate. Applying these requirements, the courts found that the petitioner had given false information and admitted doing so, so the summary procedure was validly invoked and the punishment was upheld.

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Issues: Whether the Trial Court was justified in invoking the summary procedure for perjury and punishing the petitioner for tendering false evidence and fabricating evidence.

Analysis: Section 344 of the Code of Criminal Procedure, 1973 provides an additional and alternative summary procedure to punish perjury by the very court before which the false evidence is committed. Its exercise is conditioned on three mandatory requirements: the court must form an opinion at the time of delivering judgment or final order that the witness intentionally gave false evidence or fabricated evidence, it must consider that summary punishment is in the interests of justice, and the witness must be given a reasonable opportunity to show cause. The provision is intended to deal effectively with the evil of perjury and is not meant to dilute the court's existing power to proceed under Section 340(1) where necessary. On the facts, the petitioner had lodged a false rape report, resiled from her earlier statements, and admitted giving false information in her reply to the show-cause notice. The trial court and the High Court found the statutory requirements satisfied.

Conclusion: The summary action under Section 344 was validly taken and the punishment imposed on the petitioner was upheld.

Final Conclusion: The challenge to the conviction and sentence failed, and the special leave petitions were dismissed.

Ratio Decidendi: A court may summarily punish perjury under Section 344 of the Code of Criminal Procedure, 1973 only when it forms the requisite opinion of intentional false evidence, considers summary punishment to be in the interests of justice, and affords a reasonable opportunity to show cause.

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