Pranav B Prem

The Allahabad High Court recently quashed proceedings against Chandrakant Tripathi, who had been facing charges of giving false evidence under Sections 194 and 211 of the IPC for over three decades. The Court ruled that continuing the trial after such an extended delay would be unjust, a waste of public resources, and would cause undue harassment to the accused.

Case Background

The proceedings against Chandrakant Tripathi stemmed from a complaint filed on July 21, 1992, following his testimony in a murder trial. In October 1991, the accused had lodged an FIR against one Salim under Section 302 of the IPC. Salim was acquitted in June 1992, with the trial court directing proceedings against Tripathi for allegedly not supporting the prosecution’s version during the trial. Despite the passage of 32 years, no witnesses have been examined in the case. Tripathi approached the High Court, seeking to quash the complaint, citing violations of his fundamental right to a speedy trial under Article 21 of the Constitution.

Observations by the Court

Justice Raj Beer Singh, while considering the matter, emphasized that a fair and expeditious trial is an integral part of the constitutional guarantee of life and liberty. Referring to the Supreme Court's judgments in A.R. Antulay vs. R.S. Nayak and P. Ramachandra Rao vs. State of Karnataka, the bench highlighted that the right to a speedy trial extends to all criminal proceedings, including pre-trial investigations. “The right to a speedy trial is a fundamental right under Article 21. Prolonged delays without any progress render the trial oppressive and unwarranted,” the court observed.

Key Findings

The Court noted that Tripathi had been facing trial since 1992 and that there was no evidence to suggest that he was responsible for the delay. Despite the charges being framed in 2023, the prosecution failed to examine even a single witness. Justice Singh remarked that attempting a fair trial after such a long lapse of time was impractical and would serve no meaningful purpose. The Court also held that merely initiating proceedings against the applicant for not supporting the prosecution’s case was unwarranted, particularly in the absence of credible evidence or progress in the trial.

Judicial Precedents

Citing principles laid down in A.R. Antulay and Pankaj Kumar vs. State of Maharashtra, the Court reiterated that criminal proceedings must be concluded within a reasonable timeframe to uphold the constitutional rights of the accused. The judgment highlighted that unnecessary delays not only infringe upon the accused’s rights but also undermine public confidence in the justice system.

Verdict

Considering the undue delay, the lack of progress in the trial, and the absence of any evidence against the accused, the Court deemed it appropriate to quash the proceedings. Justice Singh remarked that continuing the trial would be a waste of public resources and would unduly burden the accused, who has already faced significant hardship over the past 32 years. The application under Section 482 of the CrPC was allowed, bringing long-awaited relief to the accused.

Cause Title: Chandrakant Tripathi vs. State of U.P. 

Case No: APPLICATION U/S 482 No. - 16241 of 2024

Date: January-09-2025

Bench: Justice Raj Beer Singh

[Read/Download order]