In Brief
A trial court summoned Rajendra Prasad Yadav as an additional accused under Section 319 CrPC despite his omission from the police chargesheet, based on consistent eyewitness testimony during trial naming him as a participant in a violent attack. The High Court reversed this, conducting a mini-trial on motive and credibility. The Supreme Court upheld the summoning, clarifying that Section 319 permits courts to add persons to trial when evidence reveals complicity, even if police dropped them. The test is satisfaction more than prima facie but less than conviction-level proof. Trial courts must not conduct mini-trials at the summoning stage; examination-in-chief alone suffices as evidence. The Court reaffirmed courts' obligation to ensure guilty persons face trial, not escape due to investigative failures.
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