Framing of Charges: Prima Facie Opinion of Doctors and Witness Statements Sufficient: Delhi High Court

In a significant legal development, the court maintains that charges can be framed based on witness statements and medical opinions at the early stage of a criminal case.

In a recent judgment, the court has upheld the framing of charges against the accused in a case that involved a fatal incident. The ruling, delivered by Honorable Judge Jasmeet Singh on September 27, 2023, emphasizes the importance of a prima facie view of the matter when deciding whether charges should be framed against an accused party.

Judge Singh stated, "The Court, at the time of framing of charges, is not to scrutinize each and every material with a magnifying glass or conduct a mini trial, but it is only required to sift and weigh the evidence and take a prima facie view on framing of charge by looking into the materials placed before it."

One key aspect addressed in the judgment was the consistency of witness statements. While the defense argued that there were discrepancies in the statements provided by the sole witness, the court held that these discrepancies did not undermine the prosecution's case at the initial stage of framing charges. The judge explained, "Minor discrepancies which do not shake the basic version of the prosecution case may be discarded."

The court also clarified that rendering medical assistance to the victim was not a significant factor to consider when framing charges. Detailed examination of medical aid would be conducted during the trial. The judgment stressed that, for the purposes of framing charges, a prima facie opinion of doctors and witness statements were sufficient.

Regarding the nature of the injury inflicted on the deceased, the court cited that even a single blow, if sufficient to cause death in the ordinary course of nature, could lead to murder charges. In this case, the injury was on a vital part of the body, the head, making it plausible for the accused to be charged with murder. The court referred to a panel of seven doctors whose opinion suggested that the injury could cause death in the ordinary course of nature.

The judgment also addressed the argument that the accused had been performing their official duties. The court clarified that the duty of the accused had ceased upon the presentation of the victim's Identity Card. Therefore, no sanction was required for prosecution, as the accused's actions went beyond their official duties.

Judge Jasmeet Singh affirmed that the Special Judge had correctly assessed the facts and law, and there was no reason to interfere with the order on framing charges. The court's ruling underscores the importance of a prima facie view at the early stages of a criminal case and the role of witness statements and medical opinions in this process.

Date of Decision: September 27, 2023

JAGAT NARAYAN vs  CENTRAL BUREAU OF INVESTIGATION