eCourtsIndia

Harish Malhotra vs. State

Final Order
Court:High Court, Delhi
Judge:Hon'ble Unknown Judge
Case Status:Unknown Status
Order Date:22 Aug 2005
CNR:DLHC010127482003

AI Summary

In this criminal revision petition, Harish Malhotra challenged the charge framing order passed by the Additional Chief Metropolitan Magistrate on December 21, 2002. The Delhi High Court, after careful examination of the case record and hearing both sides, found no infirmity, perversity, impropriety, illegality, or jurisdictional error in the lower court's order and dismissed the revision petition.

Ratio Decidendi:
An order framing charges by the Additional Chief Metropolitan Magistrate, which does not suffer from infirmity, perversity, impropriety, illegality, or jurisdictional error and has not occasioned a failure of justice, should not be interfered with by the High Court in a criminal revision petition.
Obiter Dicta:
The court emphasized the importance of careful examination of the case record and the impugned order before deciding whether to interfere with a lower court's decision in a criminal revision petition.

Case Identifiers

Primary Case No:CRL.REV.P. 291/2003
Case Type:Criminal Revision Petition
Case Sub-Type:Criminal Revision - Challenge to Charge Framing Order
Secondary Case Numbers:CRL.M.A. 505/2003, 12748/2003, DLHC010127482003
Order Date:2005-08-22
Filing Year:2003
Court:High Court Of Delhi At New Delhi
Bench:Single Judge
Judges:Hon'ble R.S. Sodhi

Petitioner's Counsel

Rahul Gupta
Advocate - Appeared
Rakesh Mukhija
Advocate - Appeared

Respondent's Counsel

V.K. Malik
Advocate - Appeared

Advocates on Record

Richa Kapoor

eCourtsIndia AITM

Brief Facts Summary

Harish Malhotra was accused in FIR No. 86/2001 registered at Kotwali Police Station in 2001. The Additional Chief Metropolitan Magistrate, after examining the evidence, framed charges against him on December 21, 2002. Dissatisfied with this order, Harish Malhotra filed a Criminal Revision Petition in the Delhi High Court on April 7, 2003, challenging the charge framing order. The High Court, after hearing arguments from both sides, examined the case record and found no legal defects in the lower court's order.

Timeline of Events

2001

FIR No. 86/2001 filed at Kotwali Police Station against Harish Malhotra

2002-12-21

Additional Chief Metropolitan Magistrate framed charges against Harish Malhotra

2003-04-07

Criminal Revision Petition No. 291/2003 filed in Delhi High Court

2005-08-22

Delhi High Court heard the revision petition and delivered its order dismissing the petition

Key Factual Findings

The order dated December 21, 2002, passed by the Additional Chief Metropolitan Magistrate framing charges against the petitioner does not suffer from any infirmity, perversity, impropriety, illegality, or jurisdictional error

Source: Current Court Finding

The impugned order has not occasioned a failure of justice

Source: Current Court Finding

Primary Legal Issues

1.Whether the Additional Chief Metropolitan Magistrate's order framing charges against the petitioner suffers from any infirmity, perversity, impropriety, illegality, or jurisdictional error
2.Whether the charge framing order has occasioned a failure of justice

Questions of Law

Does the impugned charge framing order contain any legal defects that would warrant interference by the High Court in criminal revision?

Petitioner's Arguments

The petitioner, Harish Malhotra, through his counsel Rahul Gupta and Rakesh Mukhija, argued that the order dated December 21, 2002, passed by the Additional Chief Metropolitan Magistrate framing charges against him was legally defective and should be set aside. The specific grounds of challenge are not detailed in the order, but the petitioner sought to demonstrate that the lower court's order suffered from infirmity, perversity, impropriety, illegality, or jurisdictional error.

Respondent's Arguments

The State, represented by V.K. Malik, argued in support of the impugned order, contending that the Additional Chief Metropolitan Magistrate correctly examined the evidence and properly framed charges against the accused. The State sought to uphold the lower court's decision and resist the revision petition.

Court's Reasoning

Justice R.S. Sodhi, after going through the record of the case and the impugned order with the assistance of counsel for both the petitioner and the State, found that the order under challenge does not suffer from any infirmity, perversity, impropriety, illegality, or jurisdictional error, nor has it occasioned a failure of justice. The court was satisfied that the lower court's decision to frame charges was legally sound and properly reasoned. Consequently, the court found no grounds to interfere with the charge framing order.

Statutory Interpretation Method:
Literal Interpretation
Judicial Philosophy Indicators:
  • Emphasis on Procedural Regularity
  • Deference to Lower Court Findings
  • Strict Standards for Interference in Criminal Revision
Order Nature:Substantive
Disposition Status:Disposed
Disposition Outcome:Dismissed

Impugned Orders

Additional Chief Metropolitan Magistrate (ACMM)
Case: FIR 86/2001
Date: 2002-12-21

Specific Directions

  1. 1.Criminal Revision Petition No. 291/2003 and Criminal Miscellaneous Application No. 505/2003 are dismissed

Precedential Assessment

Persuasive (Other HC)

This is a single judge order from the Delhi High Court dealing with procedural aspects of criminal revision petitions. While it does not establish binding precedent for other courts, it provides persuasive guidance on the standards and grounds for interfering with charge framing orders in criminal revision petitions. The order articulates the principle that High Courts should not lightly interfere with charge framing orders unless they suffer from specific legal defects.

Tips for Legal Practice

1.Criminal revision petitions challenging charge framing orders require demonstration of specific legal defects such as infirmity, perversity, impropriety, illegality, or jurisdictional error; mere disagreement with the lower court's findings is insufficient
2.High Courts exercise restraint in interfering with charge framing orders and will only do so when the lower court's decision has occasioned a failure of justice or contains demonstrable legal errors
3.Petitioners challenging charge framing orders must carefully examine the case record and present concrete legal arguments rather than relying on general assertions of impropriety

Legal Tags

Criminal Revision Petition standards and grounds for interferenceCharge framing order review by High Court in criminal casesJudicial deference to lower court decisions in criminal revision petitionsInfirmity perversity illegality and jurisdictional error in charge framingFailure of justice as ground for interfering with charge framing orderHigh Court jurisdiction and scope of review in criminal revision petitionsAdditional Chief Metropolitan Magistrate charge framing order validityCriminal procedure standards for challenging charge framing ordersBurden and standard of proof in criminal revision petitionsAppellate and revisional jurisdiction in criminal matters India

Disclaimer: eCourtsIndia (ECI) is not a lawyer and this analysis is generated by ECI AI, it might make mistakes. This is not a legal advice. Please consult with a qualified legal professional for matters requiring legal expertise.

Order Issued After Hearing

Purpose:

First Hearing

Listed On:

22 Aug 2005

Order Text

Sr. No.Date<b>Orders</b>
IN THE HIGH COURT OF DELHI AT NEW DELHI<br>CRL.REV.P. 291/2003 & CRL.M.A.505/2003<br>$\textcolor{red}{\textbf{+}}$<br>HARISH MALHOTRA<br>Petitioner<br>Through Mr.Rahul Gupta and Mr.Rakesh Mukhija,<br>Advocate.<br>versus<br><b>STATE</b><br>Respondent<br>Through Mr. V.K.Malik, Advocate.<br><b>CORAM:</b><br><b>HON'BLE MR. JUSTICE R.S. SODHI</b><br>ORDER
$%$<br>22.08.2005
$\mathfrak{L}$CRL.REV.P. 291/2003 is directed against the order dated<br>21.12.02 of the ACMM whereby the learned ACMM has framed a charge
against the accused.
assistance of learned<br><b>With</b><br>Counsel for the<br>the
$\mathcal{P}_t$Petitioner and learned Counsel for the State, I have<br>gone
under<br>the record of the case and the order<br>through
satisfied that the<br>order<br>under<br>challenge.<br>am<br>$\mathbf{I}$
infirmity.<br>perversity.<br>suffers<br>from<br>challenge<br>no
impropriety, illegality or jurisdictional error nor has it occasioned a
failure of justice.
CRL.REV.P. 291/2003 & CRL.M.A.505/2003 are dismissed.<br>'SODHI, .
Signature <b>Not</b> Verified<br>Digitally Signed By: ANIULYA<b>AUGUST 22, 2005</b><br><b>bp</b>

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