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Summary and Analysis of Mamman Khan vs State of Haryana 2025 INSC 1113

1. Heading of the Judgment

Mamman Khan vs. State of Haryana (Criminal Appeal Nos. 4002-4003 of 2025, arising from SLP (Crl.) Nos. 1829 of 2025 & 18089 of 2024)
Date of Judgment: September 12, 2025
Coram: Justice R. Mahadevan and Justice J.B. Pardiwala
Citation: 2025 INSC 1113

2. Related Laws and Legal Provisions

This judgment primarily interprets and applies the following laws:

  • The Code of Criminal Procedure, 1973 (CrPC):
    Sections 218: Establishes the general rule that for every distinct offence, there shall be a separate charge and a separate trial.
    Sections 219 to 223: Provide exceptions to the general rule in Section 218, allowing for the joinder of charges and joint trials of persons under specific circumstances.
    Section 223(d): Specifically allows persons accused of different offences committed in the course of the same transaction to be charged and tried together.

  • The Constitution of India:
    Article 14: Guarantees equality before the law and equal protection of the laws.
    Article 21: Guarantees the right to life and personal liberty, interpreted to include the right to a fair and speedy trial.
    Article 20(2): Protects against double jeopardy, prohibiting punishment for the same offence more than once


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