Does Non-Compliance With Non-Bailable Warrant Procedures Impact the Legality of Appellate Hearings? Upholding Existing Procedural Precedent; Clarifies Duty to Ensure Accused’s Presence at Appeal Under CrPC — Binding on Lower Courts

The High Court reaffirms that compliance with non-bailable warrant procedures under the Code of Criminal Procedure is essential before hearing a criminal appeal in the accused’s absence, but does not create new law or overrule prior precedent; the ruling confirms existing practice in criminal appellate procedure, and serves as binding authority for all subordinate courts in Chhattisgarh.

 

Summary

Category Data
Case Name CRA/335/2010 of LAKHESHWAR Vs STATE OF CHHATTISGARH
CNR CGHC010128552010
Date of Registration 03-05-2010
Decision Date 28-10-2025
Disposal Nature PARTLY ALLOWED
Judgment Author HON’BLE SMT. JUSTICE RAJANI DUBEY
Court High Court Of Chhattisgarh
Precedent Value Binding on subordinate courts
Type of Law Criminal procedure
Ratio Decidendi
  • The court clarified that issuance and execution of a non-bailable warrant against the accused is a prerequisite to proceeding with appellate hearings if an accused is not present.
  • The appellant was produced from custody in pursuance of such a warrant, his presence marked, and was thereafter sent back to jail.
  • The hearing of the appeal was conducted with the express consent of both parties, following due process.
  • The judgment reaffirms routine criminal appellate procedure, without introducing new legal principles, and emphasizes formal compliance with requirements for production of accused.
Facts as Summarised by the Court
  • Accused/appellant was brought before the court pursuant to a non-bailable warrant, having been produced from Central Jail, Jagdalpur.
  • The presence of the accused was ensured and marked.
  • With the consent of both the appellant and the respondent, the appeal was heard finally.

Practical Impact

Category Impact
Binding On All subordinate courts in Chhattisgarh
Persuasive For Other High Courts

What’s New / What Lawyers Should Note

  • The court underscores the necessity of ensuring physical presence of the accused produced via non-bailable warrant before proceeding with final appellate hearings.
  • Consent of both parties is explicitly recorded before final hearing after compliance with warrant procedures.
  • The order reiterates the importance of procedural safeguards before appellate adjudication in criminal matters.

Summary of Legal Reasoning

  • The appellant was produced pursuant to a non-bailable warrant, satisfying the procedural requirement for ensuring presence during appeal.
  • The court recorded the presence of the appellant before ordering that he be sent back to jail, establishing compliance with statutory procedure.
  • Final hearing of the appeal was only undertaken after both parties consented, reflecting adherence to principles of natural justice.
  • The judgment does not alter the existing legal landscape, but reaffirms that appeals cannot be disposed without procedural compliance regarding accused’s presence.

Arguments by the Parties

Petitioner (Appellant):

  • No substantive arguments on procedure recorded; consented to final hearing after presence was secured.

Respondent (State):

  • No substantive procedural objections recorded; consented to proceeding with the appeal after accused’s production.

Factual Background

The accused/appellant, lodged at Central Jail, Jagdalpur, was brought before the High Court of Chhattisgarh pursuant to a non-bailable warrant issued on 01.09.2025. His presence was marked as required under the criminal procedure framework. With both prosecution and appellant’s counsel consenting, the appeal was heard and disposed of finally by the court.

Statutory Analysis

The judgment references application and compliance with procedures for issuing and executing non-bailable warrants within the context of final hearing of a criminal appeal. The presence of the accused, when secured via such a warrant, is a precondition for lawful adjudication, in accordance with the Code of Criminal Procedure.

Procedural Innovations

No new procedural innovations are introduced; the judgment follows established statutory procedure for securing presence of accused and recording party consent before appellate hearing.

Alert Indicators

  • ✔ Precedent Followed – Existing criminal appellate procedure affirmed; no break from established law.

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