LexSOVARAN SINGH PRAJAPATI versus THE STATE OF UTTAR PRADESH
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[2025] 2 S.C.R. 1890 : 2025 INSC 225 Sovaran Singh Prajapati v. The State of Uttar Pradesh (Criminal Appeal No(s). 259-260 of 2019) 04 February 2025 [Vikram Nath, Sanjay Karol* and Sandeep Mehta, JJ.] Issue for Consideration a. Whether the Trial Court followed the basic requirements of a fairly conducted trial, in accordance with well-established prepositions of law, before imposing death sentence upon the Appellant/Accused? b. Whether the High Court was correct in confirming the death sentence imposed by the Trial Court? Headnotes† Constitutional of India – Art.21 – Fair Trial – Article 21 of the Constitution of India – To secure a fair trial is not solitary responsibility: Held: Fair and impartial administration of justice is a treasured right protected by various enactments of law including, first and foremost, the Constitution, which under Article 21 guarantees the Right to Fair Trial – Fair and just investigation is the starting point of the fair trial process – The process is a triangulation of the rights of the accused, the victim, and the community – The process of investigation must be completed with promptitude – The Trial Court Judge must play an active role in the search for the truth, which a trial, undoubtedly must be – Bias of all nature must be eliminated – Fair trial is to be done to maintain public confidence and uphold the majesty of law – Unfair prolongation of trial is an affront to the ideal of fair trial – Fair trial is a basic human right – The main purpose of fair trial is to ensure that injustice is avoided as far as possible, but equally ‘fair trial’ is not leveraged to a point which would hinder the established procedure of CrPC – In other words, the command of the Code cannot be ignored at the behest of the prosecution or defence, in the name of fair trial – The responsibility to secure fair trial is not solitary, and lies upon the * Author [2025] 2 S.C.R. 1891 Sovaran Singh Prajapati v. The State of Uttar Pradesh judge, the investigator, the investigating agency, and counsels for either side. [Paras 10, 11] Duty of the Trial Court – Not to be Mechanical –Court must actively seek out the truth: Held: Trial Court should be an active participant to seek out the truth in a given set of circumstances to ensure that a balance is struck between the role and responsibility of prosecution as also the rights of the accused – The Court’s duty is not to merely record evidence by overlooking the object of the trial i.e. to extract the truth – The Trial Court ought to have observed and halted the proceedings, given the absence of the counsel for the defence at crucial stages of the trial; absence of adequate opportunity to examine and cross-examine the defence witnesses; and the improper, inadequate and incomplete examination of the accused under Section 313 CrPC – The course adopted by the Trial Court was mechanical and in complete ignorance of the rights of the accused and objective of the trial. [Paras 15, 15.2, 16] Appointment of Amicus Curiae – Standing of Amicus and role to be played by Amicus needs to be indicated by Trial Court in its Orders: Held: Trial Court must indicate the standing of the person appointed as Amicus Curiae. Trial Court should also indicate the role played by the Amicus in the Trial — Whether the Amicus was appointed to assist the Court or was he appointed to aid the representation of the accused? Such indications enable the Appellate Court to gain a full view of the matter, including being able to ascertain compliance of essential aspects such as continuous and qualitative legal assistance of the accused. [Para 17] Duty of the Appellate Court – Capital Punishment Cases – Heightened Responsibility: Held: An Appellate Court has to appreciate the evidence on record, after duly summoning the record of the Courts below, and then arrive at its own finding, irrespective of the order under challenge before it being of conviction or acquittal – In Capital Punishment cases, where a person’s life hangs in the balance, the High Court’s responsibility is heightened, and it must carefully examine all relevant and material circumstances before upholding the conviction and confirming the death sentence. [Paras 18, 19] 1892 [2025] 2 S.C.R. Supreme Court Reports Duty of the Prosecutor – Examine all possible angles – Collect all relevant evidence: Held: In a criminal trial, unless the law otherwise requires, the onus of proof ne
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