The court held that when the appellant is acquitted by the trial court, a pending criminal appeal becomes infructuous and is to be dismissed as such. This order affirms the established practice and offers procedural guidance for similar circumstances without introducing new law. The judgment serves as binding authority for subordinate courts within Punjab and Haryana regarding disposal of infructuous criminal appeals due to acquittal.
Summary
| Category | Data |
|---|---|
| Case Name | CRA-D/1512/2023 of NAVISH KUMAR @ NAVI Vs STATE OF PUNJAB |
| CNR | PHHC011562402023 |
| Date of Registration | 05-12-2023 |
| Decision Date | 01-09-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | MR. JUSTICE DEEPAK SIBAL, MS. JUSTICE LAPITA BANERJI |
| Court | High Court of Punjab and Haryana |
| Bench | MR. JUSTICE DEEPAK SIBAL, MS. JUSTICE LAPITA BANERJI |
| Precedent Value | Procedural; binding within the jurisdiction of the High Court of Punjab and Haryana |
| Type of Law | Criminal Procedure |
| Ratio Decidendi |
The High Court dismissed the pending criminal appeal as infructuous because the appellant had already been acquitted by the trial court. As a result, there remained no live controversy for the High Court to adjudicate. This order affirms settled procedure without pronouncement on substantive rights or legal issues. The dismissal was oral and recognized the change in status due to the acquittal, rendering the appeal unnecessary. |
| Facts as Summarised by the Court | Counsel for the appellant submitted that the appellant was acquitted by the trial court, making the present appeal infructuous. The High Court dismissed the appeal on that ground. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within the jurisdiction of the Punjab and Haryana High Court |
| Persuasive For | Other High Courts and legal practitioners handling pending criminal appeals post-acquittal |
What’s New / What Lawyers Should Note
- Reiterates that criminal appeals become infructuous upon acquittal by the trial court and should be dismissed as such.
- Offers clear procedural direction for disposal of such infructuous appeals, saving judicial time and resources.
- Can be cited to expedite disposal of appeals where similar circumstances arise.
Summary of Legal Reasoning
- The court acknowledged the submission of the appellant’s counsel that acquittal had been secured at the trial court.
- As a result, the pending criminal appeal before the High Court was rendered infructuous.
- The court, therefore, dismissed the appeal as infructuous without entering into merits or substantive legal issues.
- This reasoning is in line with the procedural approach for live controversies—if none exists, the court declines to proceed further.
Arguments by the Parties
Petitioner (Appellant):
- Submitted that the appellant had been acquitted by the trial court.
- Urged that, consequently, the present appeal was infructuous.
Respondent (State):
No separate substantive argument is recorded in the judgment text.
Factual Background
The appellant had initially filed a criminal appeal before the High Court. During the pendency of the appeal, the appellant was acquitted by the trial court. Upon this acquittal, counsel for the appellant informed the High Court of this development, resulting in the appeal being dismissed as infructuous.
Statutory Analysis
- The judgment applies general principles relating to maintainability and mootness of appeals post-acquittal; specific statutory provisions are not discussed.
Procedural Innovations
The order reaffirms established procedure for dismissing infructuous appeals post-acquittal; no new procedural innovations are introduced.
Alert Indicators
- ✔ Precedent Followed – The judgment applies and affirms existing procedural practice regarding infructuous appeals.
Citations
- No SCC, AIR, MANU, or neutral citations are mentioned in the available judgment text.
- No paragraph numbers are assigned; not specified as reportable.