The Supreme Court of India, in a groundbreaking judgment, described itself as a “search engine of truth,” emphasizing its duty to uncover facts using procedural and substantive laws. Addressing a 1994 case involving juvenility claims, the Court highlighted judicial failures and societal responsibility toward children in conflict with the law. The appellant, initially sentenced to death, was finally granted relief with directions for rehabilitation and reintegration into society, showcasing the judiciary’s commitment to truth and justice.
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NEW DELHI: The Supreme Court of India passed a significant judgment, describing itself as a “search engine of truth,” using procedural and substantive laws as its tools. This observation was made while deciding a criminal appeal filed by an individual accused of culpable homicide amounting to murder in 1994.
A two-judge bench, consisting of Justice M.M. Sundresh and Justice Aravind Kumar, stated,
“Justice is nothing but a manifestation of the truth. It is truth which transcends every other action. The primary duty of a Court is to make a single-minded endeavour to unearth the truth hidden beneath the facts. Thus, the Court is a search engine of truth, with procedural and substantive laws as its tools.”
The bench emphasized that when procedural law obstructs the discovery of truth, the Court must find ways to overcome it.
Similarly, when substantive law appears to hinder the revelation of truth, it is the Court’s responsibility to interpret the law in line with its purpose, especially in cases involving social welfare legislation.
Background of the Case
The case dated back to 1994 when the appellant was charged with culpable homicide amounting to murder. During the trial, the appellant’s age was recorded as 20 years as of March 7, 2001. He later claimed to have been 17 years old at the time of the incident, making him a juvenile under the law. However, he was illiterate, and the trial court presumed him to be an adult, sentencing him to death.
The appellant appealed to the High Court, arguing that he should have been tried as a juvenile. However, the High Court was swayed by the severity of the crime and upheld the trial court’s decision. When the case reached the Supreme Court, the appeal was dismissed, prompting the appellant to file a review petition.
This petition reiterated his juvenility claim but was also rejected. Subsequently, his parents, along with a social worker, filed a writ petition, which was dismissed. A curative petition followed and met the same fate.
The appellant’s mother then submitted a mercy petition to the President of India, which resulted in the commutation of his death sentence to life imprisonment with the condition that he would not be released until the age of 60.
In 2019, the appellant approached the High Court, challenging the presidential order. The High Court dismissed the petition, leading the appellant to approach the Supreme Court again.
Supreme Court’s Observations
The Supreme Court expressed concern over the prolonged injustice, stating,
“We are dealing with a case where grave injustice has been perpetrated, on account of the consistent failure on part of the judicial machinery to recognise and act upon the constitutional mandate vis-a-vis the plea of juvenility.”
The Court reiterated its earlier stance, noting that
“Justice is nothing but a manifestation of the truth. It is truth which transcends every other action. The primary duty of a Court is to make a single-minded endeavour to unearth the truth hidden beneath the facts. Thus, the Court is a search engine of truth, with procedural and substantive laws as its tools.”
It further emphasized,
“In its journey, the Court must discern the truth, primarily from the material available on record in the form of pleadings, and arguments duly supported by documents. It must be kept in mind that the entire judicial system is meant for the discovery of the truth, it being the soul of a decision. For doing so, a Presiding Officer is expected to play an active role, rather than a passive one.”
The Court highlighted the societal responsibility towards children in conflict with the law, stating,
“A child is a product of the present, in need of being moulded, to thrive in the future and therefore, deviant behaviour of a child in conflict with law should be a concern of the society as a whole. One must not lose sight of the fact that the child is not responsible for an act of crime, but is rather victimized by it. Such a child is nothing but an inheritor of crime, a legacy which it does not wish to imbibe. The behaviour of a child can be attributed, possibly to two counts, namely, the environment that the child grows in, and genetics.”
The Court stressed the importance of equitable treatment under Article 14 of the Constitution, noting that children from discriminatory environments deserve fair treatment.
Key Legal Observations
Regarding the appellant’s case, the Court noted,
“The statement given by the Appellant at the time of the hearing on his sentence, would also pale into insignificance, as even then he would have been a minor at the time of commission of the offence, under both the 2000 and the 2015 Acts.”
It added,
“… this is a case where the Appellant has been suffering due to the error committed by the Courts. We have been informed that his conduct in the prison is normal, with no adverse report. He lost an opportunity to reintegrate into the society. The time which he has lost, for no fault of his, can never be restored.”
Final Judgment
The Supreme Court allowed the appeal, setting aside the previous judgment. It directed the authorities to facilitate the appellant’s rehabilitation and smooth reintegration into society upon release.
The Court’s decision highlighted the critical role of truth and fairness in judicial proceedings and emphasized its commitment to upholding constitutional principles, especially in cases involving juvenility.
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