Valid guilty plea requires a clear, voluntary admission; a monosyllabic assent after not guilty cannot sustain conviction.
A conviction on a plea of guilty is sustainable only when the admission is voluntary, informed and unambiguous, and the Magistrate properly frames and explains the charge, records the plea as far as possible in the accused's own words, and decides whether to accept it. A bare monosyllabic "yes" after an earlier plea of not guilty does not by itself amount to a valid guilty plea. On the facts stated, the conviction and sentence were annulled and the matter was remitted for a fresh trial in accordance with law.
Issues: (i) Whether a conviction based on a plea of guilty is valid when the accused had earlier pleaded not guilty and the later response was only a monosyllabic 'yes' recorded in the questionnaire; (ii) whether the Magistrate complied with the mandatory requirements governing framing of charge, explanation of the charge, recording of the plea, and acceptance of guilt.
Issue (i): Whether a conviction based on a plea of guilty is valid when the accused had earlier pleaded not guilty and the later response was only a monosyllabic 'yes' recorded in the questionnaire.
Analysis: A plea of guilty is not an empty formality and must be a positive, informed, voluntary and unambiguous admission of the offence. A bare affirmative answer to a pointed question, after an earlier plea of not guilty, does not by itself amount to a valid plea of guilt.
Conclusion: The conviction based on the monosyllabic answer could not be sustained and was against the petitioner.
Issue (ii): Whether the Magistrate complied with the mandatory requirements governing framing of charge, explanation of the charge, recording of the plea, and acceptance of guilt.
Analysis: The governing procedure requires framing and explanation of charge, a clear plea from the accused, recording of that plea in the words used by the accused to the extent possible, and a judicial decision whether to accept the plea. The absence of proper recording and the casual manner in which the alleged admission was treated deprived the revisional court of assurance that guilt had been validly admitted.
Conclusion: The mandatory procedure was not complied with, so the conviction and sentence were liable to be set aside.
Final Conclusion: The conviction and sentence were annulled and the matters were sent back for a fresh trial in accordance with law.
Ratio Decidendi: A conviction on a plea of guilty is sustainable only where the plea is voluntary, informed, clearly admitted, and properly recorded by the Magistrate in compliance with the mandatory criminal procedure.
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