In a significant ruling, the Supreme Court has reaffirmed that a Magistrate’s order taking cognizance of a case need not be faulted merely because it does not contain detailed reasons. The Court emphasized that once a prima facie case is found on the basis of materials such as the case diary, there is no legal requirement for the Magistrate to provide an elaborate explanation.
The decision came in the criminal appeal Pramila Devi & Ors. vs. The State of Jharkhand & Anr., where the appellants challenged a Jharkhand High Court judgment which had set aside a cognizance order dated 13.06.2019 and sent the matter back for fresh consideration.
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The bench of Justices Sudhanshu Dhulia and Ahsanuddin Amanullah held:
“An order of the Magistrate taking cognizance cannot be faulted only because it was not a reasoned order.”
In this case, the Additional Judicial Commissioner had taken cognizance based on the perusal of the case diary and other records, concluding that a prima facie case existed under Sections 498A, 406, and 420 of the IPC, along with provisions of the SC/ST Act.
The Supreme Court referred to earlier decisions including Bhushan Kumar v. State (NCT of Delhi) and Kanti Bhadra Shah v. State of West Bengal, which settled the principle that a Magistrate need not write detailed orders at every stage of criminal proceedings.
“It is imperative that the Magistrate must have taken notice of the accusations and applied his mind to the allegations made in the police report and materials filed,” the Court reiterated.
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The bench also highlighted that the trial court is not required to test the evidence in detail at the stage of taking cognizance. That is a matter to be examined during trial, not beforehand.
Respondent No. 2, the complainant, had alleged that she was the second wife of Vishnu Sahu and had been harassed and evicted by the accused, leading to registration of FIR No. 385/2016 under various sections. The charge sheet also supported the allegations and showed material evidence against the appellants.
In conclusion, the Supreme Court held that the High Court erred in setting aside the cognizance order simply for lacking detailed reasoning.
“The order dated 13.06.2019 being in accordance with law, was not required to be interfered with by the High Court,” the bench stated while allowing the appeal.
In terms of the aforesaid, the appeal was allowed.
Case Title: PRAMILA DEVI & ORS. Versus THE STATE OF JHARKHAND & ANR.
