Continious Evaluation : 1

Case Analysis
SATYAPAL SINGH VS STATE OF MP
Academic Year : 2023-24

SUBMITTED BY: SUBMITTED TO:

VIKAS GOUD Adv. ABHILASHA MANE

BALLB, 5TH YEAR (10TH SEMESTER)
DIVISION- A
URN NO: 2018-B-26012000A
SUBJECT: CRIMINAL PROCEDURE CODE (CrPC)
 SATYAPAL SINGH VS STATE
CASE NAME :
OF MP

DATE OF JUDGEMENT : 6 OCTOBER , 2015

COURT : SUPREME COURT OF INDIA

CRIMINAL APPEAL NO. 1315

CASE NO. :
OF 2015

PETITIONER : SATYAPAL SINGH

RESPONDENT : STATE OF MP

T.S. THAKURV.GOPALA
BENCH :
GOWDA

INTRODUCTION

The Indian legal system is a dynamic tapestry of laws and precedents that aim to
ensure justice for all. One significant aspect of this system is the right to appeal,
allowing individuals to challenge and seek redressal for legal decisions that they
perceive as unjust. In the case of Satya Pal Singh v. State of Madhya Pradesh, a
crucial question arose: does the father of a deceased victim have the right to
appeal? This landmark case grappled with this issue and established important
legal precedents regarding the rights of the victim’s family to seek justice.

FACTS OF THE CASE

• On July 19, 2010, Satya Pal Singh filed a written complaint with the
Additional Superintendent of Police, Bhind, Madhya Pradesh, alleging
 that his daughter, Ranjana, had been murdered by her husband and in-
laws.
• An FIR was registered on July 27, 2010, and the case was investigated by
the police.
• On June 13, 2013, the trial court acquitted all the accused of the charges
levelled against them.
• Satya Pal Singh filed an appeal against the order of acquittal in the High
Court of Madhya Pradesh.
• The High Court dismissed the appeal on the ground that Satya Pal Singh
did not have Locus Standi to file the appeal.
• Satya Pal Singh then filed a special leave petition in the Supreme Court
of India.

RELEVANT SECTIONS

SECTION 372 OF CRPC –

No appeal shall lie from any judgment or order of a Criminal Court

except as provided for by this Code or by any other law for the time
being in force.

ISSUES RAISED

1. Whether the victim has the right to appeal against acquittals ?

2. The definition of “victim” under the Code of Criminal Procedure, 1973.
3. The role of the State in protecting the rights of victims .
CONTENTION OF THE PETITIONER

• The contention of the petitioner in Satya Pal Singh vs State of Madhya

Pradesh was that he had Locus Standi to file an appeal against the order
of acquittal under the proviso to Section 372 of the Code of Criminal
Procedure, 1973.
• The petitioner argued that he was a “victim” within the meaning of
Section 2(wa) of the Code of Criminal Procedure, 1973, and that he had
suffered harm or injury caused by the offence. The petitioner also argued
that the High Court had erred in dismissing his appeal on the ground that
he did not have Locus Standi.
• The Supreme Court agreed with the petitioner and held that he had Locus
Standi to file an appeal against the order of acquittal. The Court held that
the definition of “victim” under Section 2(wa) of the Code of Criminal
Procedure, 1973, includes “person who has suffered any harm or injury
caused by the offence”.
• The Court held that the father of a deceased victim has suffered harm or
injury caused by the offence, and therefore, he has Locus Standi to file an
appeal against an order of acquittal.

CONTENTION OF RESPONDENT

• The contention of the respondents in Satya Pal Singh vs State of Madhya

Pradesh was that the petitioner did not have Locus Standi to file an appeal
against the order of acquittal.
 • The respondents argued that the petitioner was not a “victim” within the
meaning of Section 2(wa) of the Code of Criminal Procedure, 1973, and
that he had not suffered harm or injury caused by the offence.
• The respondents also argued that the Supreme Court should not interfere
with the judgement of the High Court.
• The Supreme Court rejected the contentions of the respondents and held
that the petitioner had Locus Standi to file an appeal against the order of
acquittal.
• The Court held that the definition of “victim” under Section 2(wa) of the
Code of Criminal Procedure, 1973, includes “person who has suffered
any harm or injury caused by the offence”. The Court held that the father
of a deceased victim has suffered harm or injury caused by the offence,
and therefore, he has Locus Standi to file an appeal against an order of
acquittal.

JUDGEMENT

• The Supreme Court of India in the case of Satya Pal Singh vs State of
Madhya Pradesh held that the father of a deceased victim has Locus
Standi to file an appeal against an order of acquittal under the proviso to
Section 372 of the Code of Criminal Procedure, 1973.
• The Court held that the definition of “victim” under Section 2(wa) of the
Code of Criminal Procedure, 1973, includes “person who has suffered
any harm or injury caused by the offence”. The Court held that the father
of a deceased victim has suffered harm or injury caused by the offence,
and therefore, he has Locus Standi to file an appeal against an order of
acquittal.
 • The Court also held that the right of victims to appeal against acquittals is
a fundamental right guaranteed under Article 21 of the Constitution of
India. The Court held that the right to appeal is an essential component of
the right to a fair trial, and that it is necessary to ensure that the rights of
victims are protected in the criminal justice system.
• The judgement of the Supreme Court in Satya Pal Singh vs State of
Madhya Pradesh has been welcomed by many legal experts. The
judgement has been seen as a significant step towards ensuring that the
rights of victims are protected in the criminal justice system.
• The judgement has also been criticised by some legal experts who argue
that it gives too much power to victims and their families. These critics
argue that the judgement could lead to frivolous appeals and could
undermine the right of the accused to a fair trial.
• The judgement of the Supreme Court in Satya Pal Singh vs State of
Madhya Pradesh is a complex and controversial issue. The judgement has
been welcomed by some legal experts and criticised by others. The
judgement is likely to have a significant impact on the rights of victims in
the criminal justice system.

Here are some of the key points of the judgement:

• The definition of “victim” under Section 2(wa) of the Code of Criminal

Procedure, 1973, includes “person who has suffered any harm or injury
caused by the offence”.
• The father of a deceased victim has suffered harm or injury caused by the
offence, and therefore, he has Locus Standi to file an appeal against an
order of acquittal.
 • The right of victims to appeal against acquittals is a fundamental right
guaranteed under Article 21 of the Constitution of India.
• The right to appeal is an essential component of the right to a fair trial,
and that it is necessary to ensure that the rights of victims are protected in
the criminal justice system.

CONCLUSION

The impugned judgement and order of the High Court is not sustainable in law
and the same is liable to be set aside by this Court and the case is required to be
remanded to the High Court to consider for grant of leave to file an appeal by
the appellant as required under sub-Section (3) to SECTION 378 of Cr.P.C. and
thereafter proceed in the matter For the reasons stated supra, this appeal is
allowed by setting aside the impugned judgement and order of the High Court.

The case is remanded to the High Court to hear the appellant with regard to
grant of leave to file an appeal as the appellant is legal heir of the victim as
defined under SECTION 2 (wa) of Cr.P.C. and dispose of the appeal in
accordance with law in the light of observations made in this order as
expeditiously as possible.