Featured image for Supreme Court Judgment dated 21-01-2020 in case of petitioner name Dr. Nallapareddy Sridhar Reddy vs The State of Andhra Pradesh &
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Framing Additional Charges in Criminal Trials: Landmark Ruling on IPC Sections 406 and 420

The case of Dr. Nallapareddy Sridhar Reddy vs. The State of Andhra Pradesh & Ors. is a significant ruling concerning the power of courts to alter or add charges under Section 216 of the Criminal Procedure Code (CrPC). This case examined whether additional charges could be framed at an advanced stage of trial based on new evidence brought to light. The judgment provides clarity on the judicial approach to modifying charges in ongoing criminal proceedings.

The case originated from allegations of dowry harassment, criminal breach of trust, and cheating against Dr. Nallapareddy Sridhar Reddy by his father-in-law. The dispute arose when the complainant alleged that the accused demanded money and land transfers as dowry and later induced payment of Rs. 5,00,000 under false promises of securing a medical job in the United Kingdom.

Background of the Case

On March 10, 2011, the complainant (father-in-law of the accused) filed a First Information Report (FIR), accusing Dr. Nallapareddy Sridhar Reddy of dowry-related harassment. Initially, the charge sheet filed on June 30, 2012 contained charges under Section 498A IPC and Sections 3 and 4 of the Dowry Prohibition Act. However, during further investigation, additional witness statements revealed that the accused allegedly took Rs. 5,00,000 from the complainant under the false pretense of securing a medical job for his wife in the UK.

Based on this new evidence, an additional charge sheet was filed on April 12, 2013, recommending charges under Section 406 (Criminal Breach of Trust) and Section 420 (Cheating) IPC. However, the trial court, while framing charges, failed to consider these additional charges and proceeded only with the original charges.

Legal Issues Considered

  • Whether the trial court erred in not framing additional charges from the supplementary charge sheet.
  • Whether the High Court was correct in directing the trial court to frame additional charges under Sections 406 and 420 IPC.
  • Whether adding new charges at the final stage of the trial prejudices the accused.

Arguments of the Petitioner (Dr. Nallapareddy Sridhar Reddy)

  • The accused argued that the charges of cheating and breach of trust were not initially included in the FIR, making their addition at a later stage improper.
  • He contended that the allegations of demanding Rs. 5,00,000 lacked documentary evidence and were based on statements from biased witnesses.
  • The accused also claimed that the complainant and his daughter were doctors who knew that securing a job in the UK required clearing an exam, making the allegation of inducement baseless.
  • The accused relied on the ruling in Onkar Nath Mishra v. State, arguing that for an offense of cheating, there must be a dishonest intention at the time of making the promise.

Arguments of the Respondent (State of Andhra Pradesh)

  • The prosecution argued that Section 216 of CrPC empowers the court to add or alter charges at any time before judgment.
  • They emphasized that the supplementary charge sheet had already been filed, and the trial court’s failure to consider it was a procedural lapse.
  • The prosecution relied on Sajjan Kumar v. CBI, asserting that at the charge-framing stage, the court should only see whether a prima facie case exists, not conduct a detailed examination of evidence.

Supreme Court’s Analysis

  • The Court reaffirmed that under Section 216 of CrPC, a trial court can alter or add charges at any stage before judgment.
  • It held that the trial court’s failure to frame charges under Sections 406 and 420 IPC was an error, as the additional charge sheet had already been taken cognizance of.
  • The Supreme Court cited P. Kartikalakshmi v. Sri Ganesh to emphasize that courts must ensure that charges reflect all material facts disclosed during investigation.
  • It observed: “The phrase ‘at any time before judgment is pronounced’ in Section 216 is significant. It allows courts to rectify omissions in framing charges even at an advanced stage.”
  • On the accused’s claim of prejudice, the Court noted that additional charges merely require the court to consider more evidence and do not automatically imply conviction.

Final Judgment

The Supreme Court upheld the High Court’s decision and directed the trial court to frame charges under Sections 406 and 420 IPC. It ruled:

“There exists sufficient material to justify framing of additional charges. The trial court shall proceed accordingly.”

The ruling reinforces the judiciary’s role in ensuring that all material evidence is considered in framing charges. It also highlights that procedural lapses in charge framing can be rectified at any stage before judgment to ensure a fair trial.


Petitioner Name: Dr. Nallapareddy Sridhar Reddy.
Respondent Name: The State of Andhra Pradesh & Ors..
Judgment By: Justice Dhananjaya Y Chandrachud, Justice Hrishikesh Roy.
Place Of Incident: Andhra Pradesh, India.
Judgment Date: 21-01-2020.

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