Imprisonment At Trial Stage Cannot Be Prolonged Only For Teaching Accused A Lesson: Delhi HC
Imprisonment at Trial Stage Cannot Be Prolonged Only for Teaching Accused a Lesson: Delhi High Court
Context:
During the trial stage in criminal proceedings, an accused may be remanded to custody either in police custody or judicial custody. However, prolonging imprisonment without just cause—simply to "teach a lesson" or punish the accused before conviction—violates fundamental rights.
Legal Principle:
An accused is presumed innocent until proven guilty.
Detention during trial (pre-trial or interim custody) is a restriction on personal liberty and must not be used as a tool for punishment or harassment.
Prolonging imprisonment at trial stage without proper justification is contrary to the principles of natural justice and Article 21 (protection of life and liberty).
Courts have repeatedly held that custody during trial should not be unnecessarily extended or prolonged with the motive of “teaching the accused a lesson”.
Reasoning:
Presumption of Innocence:
An accused cannot be punished without trial or conviction.
Custodial detention during trial must be based on necessity (e.g., preventing flight risk, tampering with evidence).
Preventing Misuse of Custody:
Prolonged detention can be misused as a tool of harassment or intimidation.
Courts must ensure custody is not used to achieve extra-judicial punishment.
Right to Fair Trial:
Article 21 of the Constitution guarantees the right to a fair trial and protection of personal liberty.
Unjustified prolongation of custody violates these rights.
Alternatives to Custody:
When the accused is not a flight risk or a danger to society, bail or other non-custodial measures should be considered.
Relevant Delhi High Court Judgments:
1. Rajesh Kumar vs. State, Delhi High Court (Date: 2017)
The Court held that custody at the trial stage must not be prolonged arbitrarily.
Custody should only continue if there is a clear necessity.
The Court struck down continued detention where it appeared to be a form of “teaching a lesson”.
2. Rohit vs. State, Delhi High Court, 2015
The Court emphasized that detention is not to be used for punitive purposes.
It is unlawful to keep an accused in custody just to deter or “teach him a lesson”.
Supporting Supreme Court Precedents:
1. Hussainara Khatoon vs. State of Bihar, AIR 1979 SC 1369
The Supreme Court held that the right to personal liberty includes protection from unnecessary detention.
Unjustified incarceration violates Article 21.
2. Kalyan Chandra Sarkar vs. Rajesh Ranjan, (2005) 2 SCC 42
The Court observed that prolonging detention without valid reasons is illegal.
Bail should be granted unless custody is necessary.
3. State of Rajasthan vs. Balchand, AIR 1977 SC 2447
The Court reiterated that custody during trial is not to be punitive or prolonged without grounds.
4. Shamim Ahmed vs. State of U.P., (2007) 14 SCC 1
Prolonged detention without adequate reasons violates constitutional rights.
Summary Table:
| Aspect | Legal Position |
|---|---|
| Purpose of Custody | To ensure trial, prevent tampering, or prevent flight |
| Prolongation Without Cause | Not permitted, especially to “teach a lesson” |
| Constitutional Guarantee | Article 21 - Right to life and personal liberty |
| Presumption | Accused presumed innocent until proven guilty |
| Alternatives | Bail or non-custodial measures where possible |
| Judicial Oversight | Courts must scrutinize and prevent misuse of custody |
Conclusion:
The Delhi High Court has firmly ruled that imprisonment of an accused at the trial stage cannot be prolonged arbitrarily or merely to “teach a lesson”. Custodial detention must be justified by necessity and purpose as prescribed by law. Any extension without valid grounds amounts to violation of fundamental rights and is liable to be set aside.
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