The Supreme Court has dismissed a Special Leave Petition (SLP) challenging the refusal to summon four additional persons as accused in a criminal case involving a vehicle accident. The Court observed that the mere presence of other individuals in the vehicle, even if established, does not automatically suggest criminal intent or involvement in the alleged offence.
The Bench, comprising Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran, upheld the decisions of the Trial Court and the High Court, which had rejected the petitioner’s application filed under Section 319 of the Code of Criminal Procedure, 1973 (Cr.P.C.).
Background of the Case
The case stemmed from an FIR lodged by the petitioner, Rajjan Lal @ Rajanu. The allegation was that while the complainant was returning from his farmhouse on a bicycle with his son riding pillion, a jeep containing five named persons deliberately dashed against them, resulting in injuries to both.
Although the FIR named five individuals, the police filed a Final Report (charge sheet) only against the driver of the vehicle. Aggrieved by the exclusion of the other four named persons, the petitioner filed an application under Section 319 Cr.P.C. to summon them to face trial. The application was rejected by the Additional Sessions Court, a decision subsequently confirmed by the High Court.
Arguments and Investigation
The counsel for the petitioner vehemently argued that the collision was “stage managed” due to prior enmity. It was submitted that the petitioner and his son had clearly stated before the police that they had seen all five named persons sitting in the vehicle. The petitioner contended that the innocence or otherwise of the other four persons could only be decided in a “full-fledged trial.”
On the other hand, the State produced an investigation report. The Supreme Court noted that it had previously expressed apprehension on September 23, 2025, regarding the charge sheet being filed against only one person despite five being named in the FIR. Following this, the learned Government Advocate submitted a report indicating an “independent and objective revisit of the investigation at a higher level.” The further investigation corroborated the original findings, concluding that only the driver was involved, and the others were let off.
Court’s Observations and Analysis
The Supreme Court examined the depositions of PW-1 (the complainant) and PW-2 (his son) recorded by the Additional Sessions Court. The Bench noted that their deposition was limited to the extent that the “sole accused arrayed in the charge sheet” had driven the vehicle.
Regarding the allegations against the other four individuals, the Court observed:
“The mere presence of the other four do not establish any involvement.”
The Court further scrutinized the FIR and the statements of the eyewitnesses. It noted that while the witnesses stated they saw the vehicle with five identifiable persons while they were proceeding to the farmhouse, the collision occurred on their way back. The Court remarked:
“There is no statement that at the time of collision, the other four were inside the vehicle. Even if they were inside the vehicle, as rightly found by the Trial Court, there is nothing to suggest that there was a criminal intent on the part of the four persons travelling in the vehicle.”
On Section 319 Cr.P.C.
Addressing the legal scope of Section 319 Cr.P.C., the Bench emphasized that it is a suo motu power conferred on the Court. While it can be invoked by a complainant, its exercise depends on the satisfaction of the Court based on evidence led during the trial.
The Court held:
“The Additional Sessions Court, which has recorded the evidence, found no cause to invoke the suo motu power under Section 319 of the Cr. P.C.; which cannot be lightly invoked on the mere accusation made by the complainant.”
Decision
The Supreme Court found “absolutely no reason to interfere” with the impugned order and rejected the Special Leave Petition as being devoid of merit.
However, the Court clarified that its observations, or those made by the High Court, would not govern the proceedings before the Trial Court regarding the final disposal of the matter. The Court stated:
“We also make it clear that we have not, in any manner, opined on the guilt of the sole accused, which would have to be considered independently on the evidence led before the Court.”
Case Details:
- Case Title: Rajjan Lal @ Rajanu v. State of Uttar Pradesh & Ors.
- Case No: Special Leave Petition (Crl.) No. 6108 of 2025
- Coram: Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran
- Cited Statutes: Section 319 of the Code of Criminal Procedure, 1973
