The Supreme Court’s standardized format for cataloguing witnesses and evidence has now been formally mandated for trial courts across India, aiming to bring uniformity, clarity, and judicial discipline in criminal judgments.
While deciding a criminal appeal arising from Gujarat, the Supreme Court issued binding directions requiring every Trial Court to adopt a structured and tabulated method for recording witnesses, documentary exhibits, and material objects in criminal judgments.
The Court clarified that this uniform practice will significantly assist appellate scrutiny and ensure immediate comprehension of trial records.
A Division Bench comprising Justice Vikram Nath and Justice Sandeep Mehta observed that although some courts voluntarily annex witness and document charts, a mandatory and standardized framework is now essential for improving the legibility and analytical value of criminal judgments.
Why the Supreme Court Introduced a Standardized Format
The Court emphasised that criminal trials involve complex appreciation of evidence, and inconsistent documentation often hampers appellate review.
The Supreme Court standardized format for cataloguing witnesses and evidence is intended to act as a ready reference tool for judges, lawyers, and appellate courts, ensuring transparency and systematic evaluation of the prosecution and defence case.
The Bench directed that these formats must be followed uniformly by all Trial Courts dealing with criminal matters across the country.
Background of the Case
The appeal arose from a conviction under Sections 363, 376(2)(i), and 201 of the IPC and Sections 3 and 4 of the POCSO Act.
The prosecution alleged that the accused was last seen with a four-year-old child victim who had suffered sexual assault.
The Trial Court sentenced the accused to life imprisonment, which was later affirmed by the Gujarat High Court.
Upon reappreciation of evidence, the Supreme Court found serious lapses in investigation and held that the prosecution failed to establish an unbroken chain of circumstances.
The Court noted negligent police conduct and lack of credible evidence supporting the last-seen theory, ultimately acquitting the accused.
Mandatory Directions Issued to Trial Courts
To institutionalize judicial uniformity, the Supreme Court laid down the following directions:
- Tabulated Charts in Every Criminal Judgment: All criminal judgments must conclude with tabulated charts summarising witnesses, documents, and material objects.
- Standard Witness Chart: Each judgment must include a witness chart specifying serial number, name, and role such as informant, medical expert, investigating officer, or panch witness.
- Chart of Exhibited Documents: Trial Courts must prepare a separate table mentioning exhibit number, document description, and the witness who proved it.
- Chart of Material Objects: Material objects or muddamals must be catalogued with MO number, description, and the witness establishing relevance.
- Voluminous Evidence Cases: In cases involving extensive evidence, only relevant and relied-upon witnesses and documents may be charted, with a clear disclaimer.
- Defence Evidence Included: The same standardized format shall apply to defence witnesses and defence exhibits.
- Adoption of Specimen Format: Trial Courts shall ordinarily follow the specimen formats approved by the Supreme Court, with limited permissible deviations.
- Applicability Beyond Criminal Trials: High Courts may consider extending similar tabulated practices to civil trials involving voluminous evidence.
The Registry was directed to circulate the judgment to all High Courts for incorporation into procedural rules.
Outcome of the Appeal
The Supreme Court allowed the appeal, set aside the conviction, and acquitted the accused.
While granting relief, the Court reinforced systemic reforms through the Supreme Court’s standardized format for cataloguing witnesses and evidence, marking a procedural shift in criminal adjudication.
Case Details
- Case Title: Manojbhai Jethabhai Parmar (Rohit) v. State of Gujarat
- Neutral Citation: 2025 INSC 1433
- Bench: Justice Vikram Nath & Justice Sandeep Mehta
- Appellant: Manojbhai Jethabhai Parmar (Rohit)
- Respondent: State of Gujarat
- For Appellant: AOR Vijay Kumar, Advocate Vidushi Garg
- For Respondent: AOR Swati Ghildiyal, Advocate Rishi Yadav
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