Supreme Court Criminal Jurisdiction
Supreme Court Criminal Jurisdiction: Overview
The Supreme Court of India exercises criminal jurisdiction in three main ways:
Original Jurisdiction
Under Article 32 of the Constitution, individuals can directly approach the Supreme Court for enforcement of fundamental rights, including cases of unlawful detention, custodial torture, and other criminal matters violating rights.
Appellate Jurisdiction
Under Section 374 of CrPC, the Supreme Court can hear appeals against convictions and sentences awarded by High Courts in criminal cases, including death penalty cases.
Special Leave to Appeal (SLA)
Under Article 136 of the Constitution, the Supreme Court can grant Special Leave to Appeal against judgments of any court or tribunal, whether criminal or civil.
Advisory Jurisdiction
Under Article 143, the President may refer questions of law of public importance; rarely used in criminal law.
Key Principles in Criminal Jurisdiction
Supreme Court can intervene in miscarriage of justice.
Can ensure fundamental rights are protected even during criminal trials.
Functions as the final appellate authority in criminal matters.
Has power to issue directions to lower courts and investigative agencies to maintain fairness.
Detailed Case Laws
1. Bachan Singh v. State of Punjab (1980)
Facts: Appeal regarding the constitutionality of the death penalty.
Issue: Whether the death penalty violates Article 21.
Judgment: Supreme Court upheld the death penalty in the “rarest of rare cases,” but emphasized procedural safeguards.
Significance: Clarified Supreme Court’s role in death penalty appeals under criminal jurisdiction.
2. State of Rajasthan v. Balchand (1977)
Facts: Appellate review of conviction under IPC Section 302.
Issue: Whether High Court misapplied evidence principles in conviction.
Judgment: Supreme Court held that appellate courts have duty to reappraise evidence if miscarriage of justice is evident.
Significance: Reinforced Supreme Court’s appellate authority to correct wrongful convictions.
3. K.M. Nanavati v. State of Maharashtra (1962)
Facts: Famous murder case; appeal reached Supreme Court on legal interpretation.
Issue: Interpretation of culpable homicide vs. murder under IPC.
Judgment: Supreme Court clarified legal standards for intent and provocation, allowing appellate scrutiny.
Significance: Demonstrated Supreme Court’s role in interpreting criminal law principles in high-profile cases.
4. Hussainara Khatoon v. State of Bihar (1979)
Facts: Widespread detention of undertrial prisoners in Bihar jails.
Issue: Violation of Article 21 (right to speedy trial).
Judgment: Supreme Court ordered release of thousands of undertrials, emphasizing speedy trial as fundamental right.
Significance: Established Supreme Court’s original jurisdiction in enforcing fundamental rights in criminal cases.
5. Maneka Gandhi v. Union of India (1978)
Facts: Passport impounded; indirectly criminal liberty issue.
Issue: Applicability of Article 21 due process in government action.
Judgment: Supreme Court expanded due process and fair procedure, indirectly impacting criminal law enforcement and arrests.
Significance: Strengthened judicial oversight over executive action in criminal matters.
6. Swamy Shraddananda v. State of Karnataka (2008)
Facts: Corruption and criminal conspiracy charges in public office.
Issue: Whether High Court decisions on criminal proceedings were correct.
Judgment: Supreme Court exercised Special Leave to Appeal, quashing wrongful acquittals.
Significance: Highlighted Supreme Court’s discretionary appellate power in criminal cases.
7. Zahira Habibulla H. Sheikh v. State of Gujarat (2004)
Facts: Criminal trials related to 2002 Gujarat riots.
Issue: Fair trial and evidence preservation.
Judgment: Supreme Court intervened to ensure witnesses’ protection and trial integrity.
Significance: Shows Supreme Court’s role in supervising criminal trials for fairness and justice.
Key Takeaways
Supreme Court can intervene under original, appellate, or special leave jurisdiction in criminal matters.
Protects fundamental rights of accused and victims.
Ensures fair trial, speedy justice, and proper interpretation of criminal law.
Can quash convictions, acquit wrongfully convicted, or uphold rare sentences like death penalty.
Acts as final arbiter in cases of miscarriage of justice or procedural violation.
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