EVIDENTIARY DISCREPANCIES BETWEEN MEDICAL REPORTS AND OCULAR TESTIMONY CANNOT BE ADJUDICATED AT THE STAGE OF FRAMING CHARGES.

The applicant filed a criminal revision petition challenging an order dated 15/05/2023 passed by the X Additional Sessions Judge, Ujjain, which framed charges under Sections 302, 323, 147, 148, and 149 of the IPC

According to the FIR, on 25.07.2022, the applicant and four others assaulted Bharat and the complainant (Arjun) with iron pipes and sticks. When the complainant’s father, Karan Singh, intervened, the accused allegedly assaulted him with the intention to kill, causing him to collapse and subsequently die

The applicant contended that the deceased died of cardiac arrest, supported by a medical report showing no visible injuries, and thus a charge under Section 302 IPC was unsustainable

1. Whether the Trial Court committed a patent illegality or jurisdictional error in framing charges under Section 302 IPC despite medical reports suggesting a non-homicidal cause of death (cardiac arrest).

2. Whether the High Court, in its revisional jurisdiction, can conduct a mini-trial to evaluate contradictions between ocular testimony and medical evidence at the stage of framing charges.

The court primarily applied the principles governing revisional jurisdiction under Sections 397 and 401 of the Cr.P.C., 1973, noting its supervisory nature rather than appellate

Section 302 and Section 149 of the IPC regarding murder and common object

The court followed precedents including Amit Kapoor v. Ramesh Chander and Sanghi Bros. (Indore) (P) Ltd. v. Sanjay Choudhary, which establish that at the stage of framing charges, the court must only determine if uncontroverted allegations prima facie establish the offense, and should not conduct a roving inquiry or mini-trial

The Court observed that its revisional jurisdiction is strictly limited to correcting jurisdictional errors, patent illegalities, or manifest errors of record

It found that the FIR and Section 161 Cr.P.C. statements contained specific allegations that the accused assaulted the deceased with weapons with the intent to kill

The Court reasoned that the applicant's defense—specifically that the death was caused by cardiac arrest rather than assault—is a disputed question of fact that requires in-depth evidentiary analysis during a full trial

It held that evaluating the medical evidence against the ocular testimony at this preliminary stage would inappropriately amount to a "mini-trial," which is beyond the scope of a court framing charges or a Revisional Court

The High Court affirmed the order of the X Additional Sessions Judge, Ujjain, and dismissed the revision petition. The Trial Court was directed to proceed with the trial without being influenced by the observations made in this order