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Indian Evidence Law – Bharatiya Sakshya Adhiniyam, 2023 – Powers and Duties of a Presiding Judge in a Criminal Trial (Section 168 BSA)

Case Scenario

Imagine a murder trial where crucial witnesses give incomplete statements. The prosecutor fails to properly examine them, and the defence also does not cross-examine effectively. The trial judge merely records what is said without asking clarifying questions. The accused is convicted based on weak circumstantial evidence. On appeal, it becomes evident that the truth was never fully explored. The central question arises: Was the presiding judge justified in remaining passive, or did he fail in his judicial duty?

This issue highlights the powers and duties of a presiding judge in a criminal trial, as emphasized by the Supreme Court under Section 168 of the Bharatiya Sakshya Adhiniyam, 2023.

Powers and Duties of a Presiding Judge – Concept Explained

A presiding judge in a criminal trial:

  • Is not a silent spectator
  • Is not a mere recording machine
  • Is an active participant entrusted with discovering the truth

The judge’s primary duty is to ensure a fair trial by actively engaging in the proceedings, while maintaining strict impartiality.

Supreme Court Ruling: Ram Chander v. State of Haryana

In Ram Chander v. State of Haryana, the Supreme Court held that:


  • The duty of a trial judge is not to merely watch proceedings
  • The judge must participate by showing intelligent and active interest
  • The judge may put questions to witnesses to ascertain the truth

However, the Court laid down clear limits on this participation.

Judicial Guidelines from the Case

The presiding judge must:

  • Not encroach upon the role of the prosecutor or defence counsel
  • Avoid any sign of bias or partisanship
  • Not intimidate, frighten, or bully witnesses
  • Carry both prosecution and defence together

The Court described the judge as::
  • The captain of the team, where prosecution and defence are team members
  • Like a conductor of a choir, harmonizing all participants so justice is achieved

Statutory Basis – Section 168 of Bharatiya Sakshya Adhiniyam, 2023

Section 168 empowers the presiding judge to:
  • Put questions to any witness
  • At any stage of the trial
  • In any form necessary
  • For the purpose of discovering relevant facts
This power is meant to advance justice, not to secure conviction.

Recent Supreme Court Reminder: Dinesh Kumar v. State of Haryana

In Dinesh Kumar v. State of Haryana, the Supreme Court:

  • Set aside the conviction for murder
  • Found that the “last seen” evidence did not complete the chain of circumstances

Court’s Observations

  • Material witnesses were not properly examined or cross-examined
  • The trial court acted as a passive umpire
  • The accused were denied a fair trial
  • The truth could not be elicited

The Court reiterated that Section 168 BSA empowers and obligates judges to intervene when necessary.

Failure of Judicial Duty and Its Consequences

Because:

  • The trial judge failed to exercise powers under Section 168
  • Essential facts were not brought on record
  • Circumstantial evidence remained incomplete

The Supreme Court:
  • Granted benefit of doubt to the accused
  • Acquitted them of all charges
  • Directed their immediate release

Duties of a Presiding Judge Summarized

A presiding judge must:

  1. Actively monitor trial proceedings
  2. Ask clarificatory questions when needed
  3. Ensure all material evidence is examined
  4. Protect the rights of the accused
  5. Maintain neutrality and fairness
  6. Prevent injustice due to procedural lapses

Critical Analysis

Strengths of Judicial Participation

  1. Helps uncover the truth
  2. Prevents wrongful convictions
  3. Protects fair trial rights
  4. Improves quality of justice delivery
  5. Enhances public trust in courts


Risks and Limitations

  1. Risk of judicial overreach
  2. Possibility of perceived bias
  3. Excessive intervention may prejudice defence
  4. Requires judicial restraint and skill

Thus, participation must be balanced and judicious.


10 Illustrative Case Scenarios

  1. Judge clarifies gaps in witness testimony
  2. Prosecutor omits key question – judge intervenes
  3. Defence silent – judge ensures fairness
  4. Judge intimidates witness – conviction overturned
  5. Passive judge – appellate court criticizes trial
  6. Balanced intervention – conviction upheld
  7. Circumstantial evidence incomplete – acquittal granted
  8. Judge acts like prosecutor – bias alleged
  9. Judge harmonizes proceedings – fair trial ensured
  10. Failure to exercise Section 168 – miscarriage of justice

Relationship with Fair Trial and Natural Justice

The participatory role of a presiding judge supports:


  • Article 21 of the Constitution
  • Principles of natural justice
  • Rights of the accused and interests of society

Justice is a collective effort, but the judge is the guiding force.


Conclusion

The Supreme Court in Ram Chander v. State of Haryana and Dinesh Kumar v. State of Haryana has firmly established that a presiding judge in a criminal trial must not behave like a passive spectator. Under Section 168 of the Bharatiya Sakshya Adhiniyam, 2023, the judge has both the power and duty to actively participate in proceedings to uncover the truth.


At the same time, this power must be exercised with restraint, fairness, and neutrality. A judge who fails to engage meaningfully risks denying the accused a fair trial and allowing injustice to prevail. Ultimately, justice is a team effort, and the judge, as the captain, must ensure that the trial moves forward in harmony toward truth and fairness.


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