ValkyaEditorial

Tagged “criminal-procedure”

50 articles on criminal-procedure.

Supreme CourtSupreme Court of India

CBI v. R.R. Kishore: Section 6A of the DSPE Act was void from birth, not from 2014

A five-judge Constitution Bench held that when the Court struck down Section 6A of the Delhi Special Police Establishment Act in Subramanian Swamy (2014), the provision was not merely invalid going forward — it was void ab initio, unenforceable from the date of its insertion on 11 September 2003. The Bench rejected the Article 20(1) ex-post-facto objection because Section 6A was a procedural protection, not a penal provision creating an offence.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

Neeraj Gupta v. Pardeep Kumar Bansal (2026): a Magistrate need not record Section 244 evidence before committing a Sessions-triable complaint

Setting aside a Punjab & Haryana High Court remand, the Supreme Court held that where an offence is triable exclusively by the Court of Session, a Magistrate seized of a complaint case is not required to record full pre-charge evidence under Section 244 CrPC. The committal role under Section 209 is a 'narrow inspection hole' — administrative, not evidentiary.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Shaurya Singh v. CBI (2026): missing chargesheet copies do not give default bail under the BNSS

In one of the first Supreme Court readings of default bail under the Bharatiya Nagarik Suraksha Sanhita, 2023, the Court held that non-filing of the additional copies of the police report required by Section 193(8) BNSS does not entitle an accused to default bail. Once a Section 193(3)-compliant chargesheet is filed within the 60/90-day period, the Section 187(3) right is extinguished.

Valkya Editorial··7 min
LandmarkSupreme Court of India

State of Punjab v. Baldev Singh: the Section 50 NDPS search safeguard

On 21 July 1999, a Constitution Bench held that an empowered officer about to search a person under the NDPS Act must inform the suspect of the right to be searched before the nearest gazetted officer or magistrate, and that this safeguard is mandatory.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

Tarsem Lal v. Directorate of Enforcement: summons, custody, and the Section 45 bail bar after cognizance

On 16 May 2024 the Supreme Court held that once the Special Court takes cognizance of a PMLA complaint under Section 44(1)(b), the ED is powerless to arrest under Section 19; an accused who appears on summons is not in custody, so the Section 45 twin conditions are not attracted, and the court may instead take a bond under Section 88 CrPC.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

Vijay Rajmohan v. State (CBI): the s.19 sanction time-limit is mandatory, but delay does not quash the prosecution

On 11 October 2022 a two-judge Bench of the Supreme Court answered two questions on the sanction to prosecute a public servant under Section 19 of the Prevention of Corruption Act 1988. It held that the three-month period for deciding a sanction request — extendable by one month where legal consultation is required — is mandatory, yet that a failure to sanction in time does not vitiate or quash the prosecution. The consequence of delay is the accountability of the defaulting officer, subject to judicial review and CVC action, not the acquittal of the accused.

Valkya Editorial··8 min
Supreme Court ReferenceSupreme Court of India

Dr. Rakesh Kumar Gupta v. State of Uttar Pradesh (2026): can a referee judge on a split verdict reopen unanimous findings of guilt?

On a Section 392 CrPC reference after a split verdict, a two-judge Supreme Court Bench doubted the long-standing rule in Sajjan Singh and referred to a larger Bench the question whether a referee judge can disturb concurrent findings of guilt the original Division Bench was unanimous on. A digest of the facts, the questions referred, and why the reference matters.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

Seesa Santosh v. State of Telangana (2026): the right to travel abroad bows to the complainant's right to a speedy trial

A two-judge Bench of the Supreme Court held that an accused's wish to seek medical treatment abroad under Article 21 is not absolute and must yield to the complainant's right to a speedy trial where comparable facilities exist in India. A digest of the facts, the balancing test, and why the High Court's permission to travel was set aside.

Valkya Editorial··8 min
High Court ReferenceHigh Court of Delhi

Dr. Rita Bakshi v. Seema Bajaj (2026): when must a BNSS Magistrate hear the accused?

A single judge of the Delhi High Court has declined to decide, and instead referred to a Larger Bench, a foundational sequencing question under the new BNSS: on a private complaint, must the accused be heard under the first proviso to Section 223(1) before or after the Magistrate examines the complainant on oath. A digest of the facts, the interpretive conflict over when 'cognizance' is taken, and the questions sent up for authoritative resolution.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Nandini Satpathy v. P.L. Dani (1978): the right to silence reaches the police station

A former Chief Minister of Odisha refused to answer written police interrogatories in a disproportionate-assets case, and was prosecuted under s.179 IPC. A three-judge Supreme Court bench held that Article 20(3) operates from the stage of police interrogation, that 'compulsion' includes psychological and environmental pressure, and that an accused may have a lawyer present during examination. A digest of the facts, the holding, and the case's lineage into Selvi.

Valkya Editorial··8 min
High CourtHigh Court of Uttarakhand at Nainital

Rampal v. State of Uttarakhand: a POCSO conviction on 'no evidence at all'

The Uttarakhand High Court suspended a POCSO conviction and granted bail, terming the trial-court verdict 'more than shocking' — this was not a case of insufficient evidence but of no evidence at all, with the victim hostile and forensics unconnected to the accused.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Parvinder Singh v. Directorate of Enforcement: BNSS s.223 pre-cognizance hearing is mandatory and substantive

On 19 May 2026, a two-judge bench held that the first proviso to Section 223(1) BNSS — requiring the accused to be heard before cognizance is taken on a complaint — is a mandatory, substantive Article 21 right; cognizance without compliance is void ab initio, and the rule applies to PMLA complaints where cognizance is taken on or after 1 July 2024 even if the complaint was filed earlier.

Valkya Editorial··9 min
Supreme CourtSupreme Court of India

Subramanian Swamy v. Director, CBI: how the Constitution Bench buried the Single Directive a second time

On 6 May 2014, a five-judge Constitution Bench led by Chief Justice R.M. Lodha struck down Section 6A of the Delhi Special Police Establishment Act 1946 — the statutory revival of the executive 'Single Directive' that this Court had abrogated in Vineet Narain (1998) — as violative of Article 14. The judgment closes the doctrinal arc: an administrative immunity, struck down in 1997-98, cannot be reintroduced in legislative form when the underlying constitutional defect remains. The decision became the analytical scaffold for CBI v. R.R. Kishore (2023) and frames the still-pending challenge to Section 17A of the Prevention of Corruption Act 1988 inserted by the 2018 amendment.

Valkya Editorial··16 min
LandmarkSupreme Court of India

Asian Resurfacing v. CBI and its 2024 overruling: the rise and fall of the auto-vacation of stay orders

On 28 March 2018, a three-judge Bench held in Asian Resurfacing of Road Agency v. CBI that interim stays of trial granted by a High Court in civil and criminal proceedings would automatically vacate after six months, unless extended by a speaking order. The rule operated for almost six years before, on 29 February 2024, a five-judge Constitution Bench in High Court Bar Association, Allahabad v. State of UP held it constitutionally unsustainable and overruled it. A digest of both judgments, the practitioner architecture they produced, and the constitutional position that now obtains.

Valkya Editorial··7 min
Weekly Report

BNSS one year on: bail, custody, default release, trial in absentia, and the s.482 discretion

A year into the operation of the Bharatiya Nagarik Suraksha Sanhita, 2023, the practitioner-level architecture is now substantially visible. The Supreme Court's April 2026 disposition in Narayan v. State of Madhya Pradesh settled the s.480(3) bail-condition question. Section 187(3)'s fragmentary-custody architecture has produced a competing High Court line — the Kulkarni interpretation against the Senthil Balaji line — without a definitive Article 141 resolution. The s.482 discretion has widened, on the Chhattisgarh High Court's reading. Trial in absentia under s.356, the s.183 recording-of-statements architecture, and the s.367–369 protective regime for accused with intellectual disability have each produced their own developing doctrine. This piece reads the year's jurisprudence as one practitioner architecture.

Valkya Editorial··11 min
Weekly Report

Weekly Report: The BNSS bail framework, one year on

As the Bharatiya Nagarik Suraksha Sanhita completes its first year in force, the early picture on bail, default bail and police-station procedure is taking shape. A practitioner's scan of where the new Code has settled and where it has not.

Valkya Editorial··3 min
Supreme CourtSupreme Court of India

Mukesh Kumar Yadav v. State (UT of A&N): the appellate court that convicts must hear on sentence

A short judgment with a long reach. When the appellate court reverses an acquittal and finds the accused guilty for the first time, Section 386(a) CrPC requires it to itself hear the convict on sentence — not remit the matter to the trial court. A reading of the doctrinal point, the section it turns on, and how the rule travels onto BNSS Section 427.

Valkya Editorial··9 min
High CourtAllahabad High Court, Lucknow Bench

Kajal v. State of U.P.: the investigating officer's discretion under Section 183 BNSS

The Lucknow Bench of the Allahabad High Court has held that the investigating officer's discretion to sponsor a witness for recording of statement under Section 183 BNSS — the successor to Section 164 CrPC — is not displaced by a party's request. The investigating agency cannot be compelled to record the statement of a particular witness. A digest of the section, the holding, and what it means for the criminal-investigation framework under the BNSS.

Valkya Editorial··10 min
High CourtChhattisgarh High Court

Section 482 BNSS and the wider anticipatory-bail discretion: a Chhattisgarh High Court reading

Section 482 of the BNSS replaced Section 438 of the CrPC on 1 July 2024, but did so without reproducing the statutory guiding factors — nature of accusation, antecedents, possibility of fleeing — that the CrPC had attached. A reading of the Chhattisgarh High Court's diagnosis of what this means for the anticipatory-bail discretion, and how trial courts and the bar should approach the post-BNSS framework.

Valkya Editorial··9 min