Legal Review and Analysis of Rajjan Lal @ Rajanu vs State of Uttar Pradesh & Ors 2025 INSC 1421
Case Synopsis
Rajjan Lal @ Rajanu vs. State of Uttar Pradesh & Ors
Synopsis :- This judgment authoritatively interprets Section 319 of the Code of Criminal Procedure, 1973. It establishes that the power to summon additional accused is a discretionary suo motu power of the court, not a complainant's right. It can only be invoked upon the court's satisfaction based on "strong and compelling" evidence adduced during the trial that indicates the person's involvement in the offence. Mere naming in the FIR, allegations of presence, or prior enmity, without evidence of active participation or shared criminal intent, are insufficient to meet this high threshold.
1. Heading of the Judgment
Case Name: Rajjan Lal @ Rajanu vs. State of Uttar Pradesh & Ors.
Citation: 2025 INSC 1421 (Special Leave Petition (Crl.) No.6108 of 2025)
Court: Supreme Court of India
Bench: Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran
Date of Judgment: December 09, 2025
2. Related Laws and Sections
The judgment centers on the interpretation and application of a specific provision of criminal procedure.
Primary Statute: Section 319 of the Code of Criminal Procedure, 1973 (CrPC) – Power of a court to proceed against other persons appearing to be guilty of an offence.
Ancillary Reference: The judgment also mentions the alternative remedy of filing a "protest complaint" under the CrPC when dissatisfied with a police investigation.
3. Basic Judgment Details
A. Facts of the Case
The petitioner (complainant) and his son were injured when a jeep dashed against their bicycle. The First Information Report (FIR) named five persons, including the driver, as being in the jeep and alleged a deliberate attack due to prior enmity. However, after investigation, the police filed a chargesheet only against the driver. Dissatisfied, the petitioner filed an application under Section 319 CrPC before the trial court, seeking to summon the other four named persons as additional accused. The Trial Court and, subsequently, the High Court rejected this application. The petitioner then appealed to the Supreme Court.
B. Issues Before the Supreme Court
Whether the Trial Court and High Court erred in rejecting the application under Section 319 CrPC to summon the four other persons named in the FIR?
What is the correct legal standard for invoking the power under Section 319 CrPC?
C. Ratio Decidendi (Court's Reasoning)
The Supreme Court dismissed the Special Leave Petition, upholding the orders of the courts below. Its reasoning is structured as follows:
i. Nature and Scope of Power under Section 319 CrPC:
The Court clarified the fundamental principle that the power under Section 319 CrPC is a suo motu (on its own motion) power of the court. While a complainant can bring material to the court's attention to invoke this power, its exercise is not automatic or mandatory upon a mere accusation. The court must be satisfied, based on the evidence adduced during the trial, that a person not already an accused appears to have committed an offence. It is a discretionary and extraordinary power to be used sparingly and not on mere suspicion or accusation.
ii. Assessment of Evidence Led During Trial:
The Court examined the evidence that had already been recorded. It noted that the two key eyewitnesses (the complainant and his son), when examined as prosecution witnesses (PW-1 and PW-2), deposed only about the driver's actions. Their testimonies did not attribute any specific role, act, or criminal intent to the other four passengers. The Court agreed with the trial court's finding that mere presence of individuals in a vehicle, without any evidence of a common intention or active participation in the alleged crime, is insufficient to summon them as accused. The allegation that they were seen in the jeep earlier in the day did not prove they were present at the time of the collision or shared the driver's alleged criminal intent.
iii. Availability of Alternative Remedy and Conduct of Petitioner:
The Court noted that the trial had progressed considerably, and the petitioner was aware from the outset that the chargesheet was filed only against the driver. The petitioner did not exercise the alternative remedy of filing a protest complaint to challenge the police's decision to exclude the other four. This conduct was a relevant factor in assessing the belated attempt to invoke Section 319.
iv. Concurrence with Investigative Findings:
The Supreme Court placed significant reliance on the fresh investigation report submitted by the State, which reaffirmed the original conclusion that only the driver was involved. The Court found no perversity in this investigative conclusion or in the concurrent findings of the two courts below that no case for summoning the others was made out.
4. Core Principle of the Judgment
The Central Issue Addressed: The precise evidentiary threshold required for a court to exercise its discretionary power to summon additional persons as accused under Section 319 of the CrPC during the course of a trial.
The Supreme Court's Analysis and Clarification
This judgment provides a lucid and restrictive interpretation of Section 319 CrPC, emphasizing its role as a judicial safeguard rather than an investigative tool for the complainant. The Supreme Court performed a clear demarcation between accusation and proof.
The analysis proceeded on two critical levels. First, it reinforced the procedural character of Section 319 as a suo motu power, underscoring that the court's satisfaction is paramount and cannot be compelled by a party's insistence. This prevents the misuse of the provision to harass individuals based solely on names appearing in an FIR.
Second, and more crucially, the Court defined the qualitative standard of evidence required. It held that for Section 319 to be triggered, the evidence adduced during trial must indicate a "greater than prima facie" case or "strong and compelling evidence" of involvement. Mere naming in the FIR, or even an allegation of prior enmity, does not meet this standard. The evidence must show some active role, shared intention (common object under Section 34 IPC may be relevant), or specific act attributable to the person sought to be summoned.
In this case, the evidence failed this test entirely. The testimonies did not connect the other four passengers to the actual moment of the alleged deliberate collision. The judgment thus clarifies that Section 319 is not meant to side-step the investigation's conclusions or to allow a "trial by inclusion" without credible evidence. It is a power reserved for situations where trial evidence unexpectedly and compellingly points to the guilt of a person not initially charged.
5. Final Outcome
The Supreme Court dismissed the Special Leave Petition filed by Rajjan Lal (the petitioner). The impugned judgment of the High Court, which had confirmed the Trial Court's order rejecting the application under Section 319 CrPC, was upheld. The trial against the sole accused (the driver) was to proceed independently, uninfluenced by the observations in this order.
6. MCQs Based on the Judgment
Question 1: As per the Supreme Court in Rajjan Lal vs. State of Uttar Pradesh, what is the fundamental nature of the power conferred on a court under Section 319 of the CrPC?
A. It is a mandatory duty of the court to summon anyone named in the FIR.
B. It is a suo motu discretionary power of the court, exercisable based on evidence adduced during trial.
C. It is a right of the complainant that the court must enforce upon application.
D. It is an investigative power that allows the court to direct fresh inquiry against anyone.
Question 2: In the aforementioned case, why did the Supreme Court find no ground to summon the four other passengers under Section 319 CrPC?
A. Because they had diplomatic immunity.
B. Because the evidence led during trial (testimonies of PW-1 & PW-2) did not attribute any criminal act or intent to them, establishing only their mere presence earlier.
C. Because the offence was bailable.
D. Because the police had already granted them pardon.