Trial courts must frame specific, individual charges for each accused rather than passing composite orders.

The revisionists, Dinesh Kumar Rana (Chief Treasury Officer) and Basant Kumar Joshi, challenged an order dated 08.12.2025 passed by the Special Judge, P.C. Act, Haldwani.

The Special Judge had framed charges against both revisionists under Section 7 of the Prevention of Corruption Act, 1988, following an FIR lodged by the Vigilance Sector on 09.05.2025.

The revisionists contended that the essential ingredients of Section 7—specifically "demand" and "acceptance" of a bribe—were not established, and that their discharge applications had been rejected in a cursory manner on 01.12.2025.

Conversely, the State argued that sufficient evidence existed for a trial and that revisional jurisdiction is limited to examining jurisdictional errors or procedural impropriety rather than re-appreciating evidence.

1. Whether the factual arguments regarding the lack of evidence for "demand" and "acceptance" are maintainable at the stage of criminal revision against the framing of charges.

2. Whether the Special Judge, P.C. Act, followed the mandatory legal procedure under the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, while framing charges through a composite order against multiple accused.

Chapter XVIII of the BNSS, 2023 (corresponding to Chapter XVII of the Cr.P.C., 1973), which governs the framing of charges.

Specifically, it applied Section 234 (contents of charge), Section 235 (particulars of time, place, and person), and Section 237 (interpretation of words in charge).

The Court emphasized the principle that a charge must provide the accused with clear written notice of the precise nature of allegations to ensure a fair trial and effective defense.

Section 246 of the BNSS (corresponding to Section 223 Cr.P.C.) mandates that even if accused persons acted jointly, the charge for each must be specific regarding their individual roles.

The High Court first determined that arguments regarding the sufficiency of evidence (such as the lack of voice recordings or the conduct of shadow witnesses) are matters for trial and cannot be adjudicated in a revision petition.

However, the Court found a significant procedural lapse in the trial court's "composite order" of framing charges.

The Court reasoned that framing a charge is a critical stage where the judge must apply judicial mind to ensure each accused is informed of their specific role, name, time, and place of the alleged offense.

By issuing a singular, combined order without distinct written accusations and individual explanations for each revisionist, the Special Judge overlooked the mandate of Chapter XVIII of the BNSS.

The Court held that the Special Judge failed to apply judicial mind and overlooked the statutory requirements for framing specific charges.

The matter was remitted to the Special Judge, P.C. Act, Haldwani, with a direction to pass a fresh order strictly adhering to Chapter XVIII of the BNSS, 2023, within one month.

Additionally, the Registry was directed to circulate the judgment to all subordinate courts in Uttarakhand to ensure procedural compliance in future cases.