Justice Cannot Be Left to Guesswork: Supreme Court Mandates Structured Judgments in Criminal Trials Across India

“Trial Courts Must Move From Narrative to Legal Precision—Evidence Must Be Charted, Not Recalled from Memory,” In a judgment that is likely to change the way criminal trials are documented and adjudicated across India, the Supreme Court on December 15, 2025, in Manojbhai Jethabhai Parmar v. State of Gujarat, issued binding nationwide directions to all trial courts to adopt structured formats in criminal judgments, to ensure accuracy, clarity and evidentiary accountability.

While acquitting the appellant, who had been sentenced to life imprisonment under the POCSO Act for the alleged rape and attempted murder of a 4-year-old child, the Court held that the miscarriage of justice in the case was not merely due to a flawed investigation, but equally due to the absence of judicial structure and evidentiary clarity in the trial court’s reasoning.

“A criminal court must function as a court of law, not as a scribe of witness narratives. Legal reasoning must flow from verified evidence—not from memory or confusion,” the Bench of Justice Vikram Nath and Justice Sandeep Mehta observed, while directing all trial courts to follow a uniform system of documenting and analysing criminal evidence.

“A Criminal Judgment Is Not A Story—It Is A Legal Verdict That Must Carry Evidentiary Weight”

The Court observed that the trial court’s conviction in the case had stemmed from a mechanical and disorganised appreciation of evidence, where material inconsistencies, contradictions, and unreliable witness conduct were completely overlooked, and no structured analysis of exhibits, witness roles, or forensic findings was undertaken.

“In absence of an evidentiary framework, crucial links in the prosecution’s case get either assumed or glossed over. This is not merely poor drafting—it is dangerous adjudication,” the Court said.

The justices warned that when trial courts rely on unorganised recollection rather than structured documentation, wrongful convictions are not only possible—they become inevitable.

“Truth Must Be Mapped—Not Inferred”: SC Prescribes Mandatory Charts in All Criminal Judgments

To correct this systemic issue, the Supreme Court laid down that every criminal trial court judgment in India must compulsorily include three evidentiary charts:

First, a Witness Chart, listing:

• Names of all witnesses
• Their prosecution witness numbers (e.g., PW-1, PW-2)
• Their role in the case (e.g., eye-witness, investigating officer, medical examiner, panch witness, etc.)

Second, an Exhibit Chart, detailing:

• All documentary exhibits (FIR, seizure memos, medical reports, FSL reports, confessional statements, etc.)
• The name of the witness through whom the document was proved

Third, a Material Object Chart, indicating:

• All physical evidence (clothes, weapons, blood samples, etc.)
• The person who recovered them and the witness who proved them in court

“The evidence must be traceable, verifiable, and legally proved through the record—not assumed or summarised vaguely,” the Court said, making it clear that such a framework is no longer optional, but binding.

“This Is Not Merely a Procedural Directive—It Is A Constitutional Imperative Against Arbitrary Convictions”

The Court emphasised that such structure is essential for ensuring constitutional due process under Articles 20 and 21, which require that no person shall be deprived of liberty except by procedure established by law.

“Justice must not only be done—it must be recorded, structured, and justified. Vague appreciation of evidence is as dangerous as no appreciation at all,” the bench held, stressing that legal precision in trial court orders is not a matter of good practice, but of fundamental rights.

The judgment makes it clear that failure to adopt such structuring may amount to a denial of fair trial, and could render convictions vulnerable on appeal.

“Registry To Circulate This Format To All High Courts—Implementation Shall Be Statewide”

The Court directed its Registry to circulate a copy of this judgment to the Registrar Generals of all High Courts, with instructions to ensure that all trial judges handling criminal matters are informed of this new format.

Further, the Court encouraged High Courts to expand this framework to complex civil litigation, especially in cases involving multiple parties, extensive documentary evidence, or forensic findings.

“Orderly structure is not a burden—it is the basic discipline of adjudication,” the Court remarked.

“The Cost of Unstructured Judgments Is Paid In Lost Years, Broken Lives, and Miscarried Justice”

This direction came in the backdrop of the appellant Manojbhai Jethabhai Parmar’s acquittal, after he had spent 13 years behind bars for an offence the Court found to be completely unproved. From fabricated last-seen theories to unproved forensic links, the conviction was ultimately a result of both a careless investigation and a judicial process lacking evidentiary rigour.

“This is not an isolated case—it is an echo of hundreds where justice is lost in the haze of sloppy reasoning and inconsistent record-keeping,” the Court observed, adding that structured judgments are the first step towards ensuring that truth is not lost in procedural fog.

A Transformative Step Towards Criminal Justice Reform

This direction is likely to bring uniformity, discipline, and enhanced transparency in trial-level criminal adjudication—a step that has long been awaited by legal practitioners, appellate courts, and scholars.

The judgment sets a new standard in trial court accountability, ensuring that every conviction or acquittal stands on a legally traceable and documented evidentiary foundation.

“Justice must not rest on the memory of the judge—it must be visible in the structure of the judgment,” the Court concluded.

Date of Decision: 15 December 2025