Satbir Singh vs Rajesh Kumar 2025: Supreme Court Case

Satbir Singh vs Rajesh Kumar 2025 case gained attention as it raised important questions on the evidentiary standard under Section 319 of Criminal Procedure Code especially whether a court can summon an accused based solely on a victim’s oral testimony despite a police closure report. It reiterated the principles from Hardeep Singh v. State of Punjab on interpretation of “evidence” under Section 319 Cr.P.C. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Satbir Singh vs Rajesh Kumar 2025 Introduction

Satbir Singh vs Rajesh Kumar 2025 is a landmark judgment delivered by the Supreme Court interpreting the scope and application of Section 319 of Criminal Procedure Code, 1973. The case dealt with the power of a Trial Court to summon additional accused during trial especially based on the statement of an injured eyewitness despite the absence of incriminating material in police investigation reports.

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The case at hand centres around the scope and application of Section 319 of Criminal Procedure Code, especially whether a Trial Court can summon additional accused during trial based only on the testimony of the injured eyewitness, despite previous police investigations finding no material evidence against them. It raised important questions regarding judicial discretion, evidentiary thresholds and the balance between protecting innocent individuals and ensuring justice for the victim. The following are the facts of Satbir Singh vs Rajesh Kumar -

Incident and Initial Medical Condition

On 9th February 2020, police at P.S. Sadar, Karnal received information that Satbir Singh (Appellant) and Mukesh (another accused) had sustained injuries from an assault and were admitted to Civil Hospital, Karnal and Ram Chander Memorial Hospital, Karnal, respectively. The police attempted to record their statements on 9th and 10th February 2020 but both individuals were medically unfit to give any statements.

Mukesh’s Statement and FIR

On 12th February 2020, doctors discharged Mukesh and the Investigating Officer (IO) recorded his statement. Based on his account, the police registered an FIR. The IO obtained an X-ray report of Mukesh which confirmed a fracture. However, the medical opinion suggested that Mukesh could have sustained the injuries himself. Consequently, the IO concluded that allegations by Mukesh against Satbir Singh were unsubstantiated and submitted a closure report.

Appellant’s Statement and Cross-Case

On 14th February 2020, doctors declared Satbir Singh fit for statement. He disclosed that he was an Indian Army serviceman visiting his village on leave. While playing volleyball on 9th February 2020 at around 2:30 p.m., he had an altercation with Mukesh who slapped him during the game. The teammates separated them but Mukesh returned after 15 minutes with Rajesh Kumar, Neeraj, Sagar @ Bittoo and Ankit armed with a knife, lathis and dandas.

According to the Appellant, Neeraj held him while Mukesh stabbed him in the waist and near his heart, causing injuries that penetrated to his lungs. Sagar and Ankit assaulted him with lathis and dandas. Rajesh Kumar threatened him and warned him that he would be killed if he returned to the village. The Appellant claimed he fell unconscious due to heavy bleeding and that Amarjeet and Jai Singh brought him to the hospital.

Medical Reports and Registration of Cross-Case

The Medico Legal Report (MLR) of the Appellant revealed two sharp-weapon injuries, one of which (on the chest) was declared ‘dangerous to life.’ Based on his statement and medical findings, the police registered a cross-case under Section 323, Section 324, Section 307, Section 506 and Section 34 of Indian Penal Code against Mukesh, Rajesh Kumar, Neeraj, Sagar @ Bittoo and Ankit. On 28th February 2020, police recovered the knife used by Mukesh following his disclosure.

Investigation and Filing of Chargesheet

Despite the allegations by the Appellant, the IO did not find any evidence against Rajesh and Ankit. The Station House Officer (SHO) along with three Deputy Superintendents of Police (DSPs) from Karnal independently investigated the matter and concluded that Rajesh, Neeraj, Sagar @ Bittoo and Ankit had not participated in the assault. The police arrested Mukesh on 28th February 2020 and later filed a final report under Section 173(2) of Criminal Procedure Code against him under Section 307, Section 323, Section 324, Section 506 and Section 34 IPC.

Framing of Charges and Testimony of Appellant

On 4th March 2021, the Sessions Judge framed charges under Section 324, Section 307 and Section 506 of Indian Penal Code and Section 25 of the Arms Act against Mukesh. The prosecution listed 14 witnesses and on 27th April 2021, Satbir Singh testified as PW-1. He reiterated his allegations against Mukesh and named Rajesh, Neeraj, Sagar @ Bittoo and Ankit as co-accused. Based on this, he filed an application under Section 319 of CrPC to summon them as additional accused.

Revisional Proceedings and High Court Ruling

The Sessions Judge allowed the application filed by the Appellant, prompting Rajesh, Sagar @ Bittoo, Neeraj and Ankit to challenge the order before the High Court. On 7th March 2024, the High Court set aside the order of the Session Court dated 13th September 2021. The High Court ruled that medical records did not support the allegations against the four individuals and noted that multiple police investigations had consistently found their non-involvement. Thus, the Court ruled there was insufficient material to summon them for trial under Section 319 CrPC.

Satbir Singh vs Rajesh Kumar 2025 Legal Issues

The following issues were addressed in Satbir Singh vs Rajesh Kumar 2025 -

• Stage at which Section 319 CrPC can be invoked: The main issue was whether the Supreme Court can exercise powers under Section 319 of Criminal Procedure Code during the stage of inquiry or only after the trial has commenced?
• Interpretation of the term “evidence” under Section 319(1) CrPC: The Supreme Court also examined whether “evidence” includes only evidence recorded during trial or also includes materials collected during investigation or examination-in-chief?
• Necessity of cross-examination before summoning additional accused: The Court in Satbir Singh vs Rajesh Kumar also analysed whether the evidence must be tested by cross-examination before a person can be summoned under Section 319 CrPC?

Section 319 of Criminal Procedure Code played an important role in Satbir Singh vs Rajesh Kumar 2025. The following is the analysis of this provision -

• Section 319 of Criminal Procedure Code

Section 319 (Now Section 358 of Bharatiya Nagarik Suraksha Sanhita, 2023) deals with the power to proceed against other persons appearing to be guilty of offence. It states that -

1. Where, in the course of any inquiry into, or trial of, an offence, it appears from the evidence that any person not being the accused has committed any offence for which such person could be tried together with the accused, the Court may proceed against such person for the offence which he appears to have committed.
2. Where such person is not attending the Court, he may be arrested or summoned, as the circumstances of the case may require, for the purpose aforesaid.
3. Any person attending the Court, although not under arrest or upon a summons, may be detained by such Court for the purpose of the inquiry into, or trial of, the offence which he appears to have committed.
4. Where the Court proceeds against any person under sub-section (1), then -

1. the proceedings in respect of such person shall be commenced afresh, and the witnesses re-heard
2. subject to the provisions of clause (a), the case may proceed as if such person had been an accused person when the Court took cognizance of the offence upon which the inquiry or trial was commenced.

Satbir Singh vs Rajesh Kumar 2025 Judgment and Impact

On 1st April, 2025, the 2-Judge Bench of the Supreme Court comprising Justice Dipankar Datta and Justice Manmohan in Satbir Singh vs Rajesh Kumar ruled in favour of the Appellant and set aside the impugned order of the High Court and restored the order of Sessions Judge of summoning the additional accused under Section 319 of Criminal Procedure Code.

The Supreme Court reaffirmed the well-settled legal position laid down in the judgment of Hardeep Singh v. State of Punjab. It reiterated that the Trial Court can summon an additional accused at any stage during the inquiry or trial based on material that satisfies a test stronger than mere prima facie evidence, but not as strict as that required for conviction. 

The Supreme Court in Satbir Singh vs Rajesh Kumar explained that the term “evidence” under Section 319 of Criminal Procedure Code includes not only material tested through cross-examination but also examination-in-chief and that such summoning does not require waiting until evidence is cross-examined.

In this case, the Sessions Judge exercised his discretion after forming the requisite level of satisfaction based on the eyewitness testimony of the injured complainant. He noted that there was substantial material to summon Rajesh and Neeraj despite police reports that did not charge them. The Supreme Court ruled that the conclusion of the Session Court was plausible and legally sustainable and not mechanical or arbitrary.

The Supreme Court in Satbir Singh vs Rajesh Kumar observed that the High Court erred by interfering with the discretionary order of the Sessions Judge without properly appreciating the standard of satisfaction required under Section 319 of Criminal Procedure Code. It highlighted that the High Court ought to have adopted a ‘hands-off’ approach particularly when the order of the Sessions Court had substantive legal backing and did not suffer from perversity or illegality.

On the basis of the above findings, the Supreme Court in Satbir Singh vs Rajesh Kumar allowed the appeal, restored the order of the Sessions Court and directed the Trial Court to proceed with the case expeditiously and in accordance with law.

Conclusion

In Satbir Singh vs Rajesh Kumar 2025 the Supreme Court on 1st April, 2025 reinforced the power of Trial Courts to summon additional accused during trial based on credible and substantive evidence, even if it conflicts with police findings. By explaining that examination-in-chief can qualify as “evidence” under Section 319 of Criminal Procedure Code and that cross-examination is not mandatory before exercising this power the judgment bolsters the role of the judiciary in ensuring justice.