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Supreme Court of India 2019-12-18 allowed

ANOKHILAL vs THE STATE OF MADHYA PRADESH

Bench: 3 — Uday Umesh Lalit, Indu Malhotra, Krishna Murari

In Brief

A nine-year-old girl was reported missing in January 2013 in Madhya Pradesh and was later found dead. The appellant was arrested and charged with kidnapping, rape, murder, and sexual abuse of a child. He was convicted and sentenced to death by the trial court, with the High Court confirming the sentence. However, the Supreme Court set aside the convictions and ordered a fresh trial, holding that the appellant was denied fair trial. An Amicus Curiae was appointed on the same day charges were framed, affording no time for the counsel to prepare or consult with the accused. This breached Article 21's guarantee of fair procedure and Article 39-A's constitutional mandate for meaningful legal aid. The Court emphasized that while expeditious trials are desirable, they cannot sacrifice fundamental fairness principles, especially in capital cases.

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Criminal Procedure Right to Legal Aid Fair Trial Constitutional Law Death Penalty Article 21 Article 39-A Miscarriage of Justice

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