Challenging the High Court's Order in a Criminal Case: The Case of Ritu Rai vs State of Uttar Pradesh

The case of Ritu Rai vs State of Uttar Pradesh revolves around the issue of verifying the age of the appellant, Ritu Rai, in a criminal case concerning serious charges including rape, under the Indian Penal Code (IPC). The appellant filed an appeal against a decision by the High Court of Allahabad, which had set aside the Trial Court’s order. The decision of the Supreme Court in this case raises important questions about the admissibility of documents and the role of witnesses in criminal trials.

Background of the Case

Ritu Rai, the appellant, is the informant in a case registered at the Police Station Sihani Gate, Ghaziabad, Uttar Pradesh, under Sections 328, 376, 504, and 506 of the Indian Penal Code. These sections pertain to offenses including administering a stupefying substance, rape, intentional insult, and criminal intimidation, respectively. The crime was reported in 2016, and the corresponding criminal case, Criminal Case No. 192 of 2019, was subsequently registered.

During the pendency of the trial, the appellant filed an application with the Trial Court requesting that the Principal/In-Charge Officer of Kendriya Vidyalaya No. 4, DLW Campus, Varanasi, be summoned to testify regarding the veracity of her Class-X mark sheet. The appellant’s aim was to verify her age, which could have significant implications for the type of offense that could be applied if the charges were proven.

The Trial Court accepted the application, and the concerned officer was summoned as a witness. This allowed for the production of the appellant’s mark sheet in the record of the case. Although the appellant’s Admit Card had already been submitted, the summoning of the officer led to the inclusion of the mark sheet as additional evidence.

The Dispute and Appeal

The accused/respondent No. 2 in this case challenged the Trial Court’s order in an application before the High Court of Allahabad. The High Court, after considering the arguments, decided to set aside the Trial Court’s order. Despite the fact that the mark sheet had been placed on record after the officer testified, the High Court’s order effectively nullified the Trial Court’s decision to accept the document.

The appellant, Ritu Rai, then filed an appeal before the Supreme Court, challenging the High Court’s order. The issue at hand was whether the High Court had correctly set aside the Trial Court’s decision and whether the mark sheet, now on record, could be used as evidence in the case.

The Appellant’s Argument

Ritu Rai’s counsel argued that the Trial Court had rightly allowed the application for summoning the concerned officer and producing the mark sheet as evidence. The appellant contended that the verification of her age was crucial to the case, especially since it could affect the nature of the charges under the IPC. The appellant maintained that the Trial Court had followed the correct procedure by allowing the officer to testify, and the document had been placed on record in compliance with legal procedures.

Furthermore, the appellant’s counsel emphasized that the High Court’s decision to set aside the order was erroneous and unjust. The evidence had already been presented in the trial, and the appellant argued that there was no valid reason to discard it at this stage, particularly when it had been submitted in good faith and had been duly examined by the relevant authorities.

The Respondent’s Argument

The respondent, representing the State of Uttar Pradesh, did not specifically contest the inclusion of the mark sheet but rather focused on the procedural aspect of the case. The respondent argued that the High Court’s decision to set aside the Trial Court’s order was justified, as the Trial Court had acted beyond its powers in summoning the officer and admitting the mark sheet as evidence. The respondent contended that the legal requirements for accepting such evidence had not been properly followed.

Additionally, the respondent argued that the appellant had failed to establish the necessity of the mark sheet at this stage of the trial. While acknowledging the relevance of age in certain criminal cases, the respondent maintained that the document in question was not crucial to the resolution of the case at hand and that the High Court’s ruling should be upheld.

The Court’s Analysis

The Supreme Court, while examining the case, focused primarily on the procedural correctness of the actions taken by the Trial Court and the High Court. The Court noted that the Trial Court had acted within its jurisdiction by allowing the appellant’s application and summoning the officer to testify about the mark sheet’s authenticity. The Court also acknowledged that the inclusion of the mark sheet was an important step in verifying the appellant’s age, which could potentially influence the outcome of the case.

In its judgment, the Supreme Court emphasized the importance of allowing relevant evidence to be presented in criminal trials. The Court stated that the Trial Court had correctly accepted the document based on the testimony of the concerned officer, and there was no legal justification for the High Court to set aside the order. The Court pointed out that the Trial Court had followed the established legal procedures, and the High Court’s decision to overturn the order was not supported by sufficient legal grounds.

Final Judgment

The Supreme Court allowed the appeal, setting aside the High Court’s order and restoring the Trial Court’s decision. The Court directed that the mark sheet, which had already been placed on record, should remain part of the evidence in the ongoing criminal case. The Court emphasized that the appellant had the right to present all relevant evidence in her defense and that the trial should proceed in accordance with the legal principles established under the Code of Criminal Procedure (CrPC).

Significance of the Judgment

This judgment is significant in reaffirming the importance of allowing relevant and admissible evidence in criminal trials. It also highlights the procedural fairness that must be maintained throughout the judicial process, ensuring that parties have the opportunity to present their case with all available documentation. The decision reinforces the principle that courts must act within their jurisdiction and that the High Court’s powers to overturn lower court decisions should be exercised with caution.

The ruling also underscores the flexibility of the judicial system in allowing parties to introduce evidence that may have a substantial impact on the trial’s outcome, particularly when it pertains to important issues such as the age of a victim or defendant. This decision can be seen as a reminder of the importance of ensuring that justice is not hindered by procedural technicalities but rather guided by the substance of the case at hand.

Petitioner Name: Ritu Rai.
Respondent Name: State of Uttar Pradesh.
Judgment By: Justice Uday Umesh Lalit, Justice J.B. Pardiwala.
Place Of Incident: Ghaziabad, Uttar Pradesh.
Judgment Date: 29-09-2022.

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