1999 (7) TMI 706 - SC - Indian Laws

Supreme Court quashes High Court intervention in criminal trial, emphasizes timely justice delivery.

Arun Shankar Shukla Versus State of Uttar Pradesh and Ors.

The Supreme Court held that the High Court's intervention under Section 482 of the Criminal Procedure Code, which stalled the trial process and allowed ... - Issues Involved:High Court's exercise of inherent jurisdiction under Section 482 of the Criminal Procedure Code preventing the flow of justice due to alleged misconduct of a judicial officer.Detailed Analysis:Issue 1: High Court's Exercise of Inherent JurisdictionThe Supreme Court examined the High Court's exercise of inherent jurisdiction under Section 482 of the Criminal Procedure Code. It noted that while the High Court has powers to prevent abuse of process or secure justice, these powers are not unlimited. The Court emphasized that inherent powers should be sparingly used and not invoked if there are specific provisions in the law covering the matter. In this case, the High Court's intervention at a critical stage of the trial, where convicted accused had the right to appeal, was deemed inappropriate. The High Court's actions were seen as stalling the course of justice and bypassing the legal procedures available to the accused.Issue 2: Delay in ProceedingsThe accused-respondents were charged with serious offenses, and the trial proceedings dragged on for a significant period. After the judgment was pronounced, the accused failed to appear for sentencing, leading to non-bailable warrants being issued against them. Instead of complying, the accused filed a petition under Section 482 of the Code in the High Court, which resulted in a stay on the warrants. The subsequent delays in the High Court's hearings and adjournments further prolonged the process, allowing the accused to evade arrest and manipulate the system.Issue 3: Abuse of Process and Judicial SystemThe informant-injured witness contended that the accused, convicted of murder, had abused the court process by avoiding arrest through misrepresentations and obtaining stay orders. The Supreme Court acknowledged this abuse and directed that the High Court's order staying the arrest be put in abeyance, making the accused liable for surrender or imprisonment. The Court expressed concern over the accused misleading the judicial system and causing delays in the legal proceedings, emphasizing the need to prevent such misuse of the legal process.Conclusion:The Supreme Court allowed the appeal, quashing the High Court's order under Section 482 and directing the Sessions Judge to proceed with sentencing the accused according to law. The accused were ordered to remain in jail until sentencing. The Court clarified that the High Court could address any contentions raised by the accused in their appeal or administratively, without being bound by the observations made in the Supreme Court's judgment.