Landmark Judgment Mandating Standardized Format for Trial Court Judgments
It must be certainly acknowledged with grace and gratitude that in a most praiseworthy initiative that will definitely have long-term ramifications in streamlining the appreciation of evidence in criminal trials, the Supreme Court in a most learned, landmark, laudable, logical and latest judgment titled Manojbhai Jethabhai Parmar (Rohit) vs State of Gujarat in Criminal Appeal No(s) 2973 of 2023 and cited in Neutral Citation No.: 2025INSC1433 that was pronounced most recently on December 15, 2025 has issued mandatory directions to all the Trial Courts across the nation to adopt a “standardized format” for judgments.
It issued these mandatory directions to all the Trial Courts all across the nation aimed to institutionalize a standardized format for cataloguing witnesses, documentary evidence and material objects to ensure systematic presentation of evidence that enables efficient appreciation of case records in a criminal trial!
It must be laid bare that the Apex Court Bench laid down the format while acquitting a man of the serious allegation of a brutal sexual assault of a four-year-old finding the conduct of the police officers who conducted the investigation of the case to be “highly pedantic and gravely negligent”.
Purpose and Scope of the Common Guidelines
It must be noted that the Apex Court said that the common guidelines will serve to facilitate better comprehension and immediate reference for all stakeholders, including the appellate courts – High Courts and Supreme Court.
It was also clarified by the top court that in complex cases, such as conspiracies, economic offences or trials involving voluminous oral or documentary evidence, where the list of witnesses and exhibits are substantially long, the Trial Court may prepare charts only for the material relevant, and relied upon witnesses and documents, so that the charts do not become “unwieldy compilations”. Very rightly so!
Case Background and Procedural History
It must be borne in mind that the case before the Court involved allegations against one Manojbhai Parmar who was accused of rape and sexual assault on minor girl under various provisions of the Indian Penal Code and the Protection of Children from Sexual Offences Act.
It must also be taken into account that the case was registered in 2013 at Kalol police station in Gujarat and both the Trial Court and Gujarat High Court upheld the life sentence awarded to him.
We thus see that following the Apex Court’s acquittal, he will get to walk out of the jail after 12 years!
It would be pertinent to note that while concluding that the trial was conducted with “pedantic rigidity” that obscured the truth, the Apex Court thus acquitted the appellant of all charges, setting aside the concurrent judgments of the Trial Court and the Gujarat High Court.
Opening Observations by the Apex Court
At the very outset, this brief, brilliant, bold and balanced judgment authored by Hon’ble Mr Justice Sandeep Mehta for a Division Bench of Apex Court comprising of Hon’ble Mr Justice Vikram Nath and himself sets the ball in motion by first and foremost putting forth in para 2 that,
“A grave and distressing case of brutal sexual assault upon a four-year old girl (Hereinafter, being referred to as ‘child victim’) stands before this Court, enveloped in layers of investigative apathy and procedural infirmities. The First Information Report, despite the informant’s professed complete knowledge of the incident, is bereft of even the most rudimentary details, neither the name of the accused person (appellant herein) nor those of the purported witnesses of the last seen together circumstance find mention. What followed was an investigation hopelessly botched and a trial conducted with a pedantic rigidity that obscured, rather than unveiled, the truth. The highly unnatural conduct of the witnesses, marked by gross insensitivity/rank apathy, contradictions and apparent concoctions raises serious doubts about the reliability of the prosecution’s case. Yet, in face of this disturbing matrix, the accused-appellant stands convicted and has remained behind bars for nearly thirteen long years.”
Systemic Impact of Flawed Investigations and Trials
Most forthrightly, the Apex Court propounds in para 3 holding that,
“This Court cannot remain oblivious to the sobering reality that such handling of criminal cases leaves scars not merely upon the individuals involved but upon the justice system itself. When investigations are carried out in a manner that betrays their foundational purpose, and trials become mechanical exercises divorced from the quest for truth, the resulting miscarriage of justice reverberates far beyond the confines of the courtroom. It erodes public faith, instills uncertainty in victims, and sends a chilling message to society at large that the pursuit of justice may falter not at the altar of complexity but at the hands of indifference. The criminal law, which must stand as a bulwark protecting the vulnerable, risks becoming an instrument of unintended cruelty when procedural lapses and institutional negligence overshadow substantive justice. With this prelude, we now proceed to examine the factual matrix of the case.”
Failure to Prove Ownership and Validity of Recoveries
Be it noted, the Division Bench notes in para 74 that,
“The prosecution also failed to establish that the house at Oad Faliya belonged to or was in the possession of the accused-appellant. Hareshbhai Pallacharya (PW-15) admitted in his evidence that he did not collect any evidence proving ownership. Pankajkumar Darji (PW-14) also admitted the same and even the Circle Officer, Bharatkumar Mahajan (PW-12) conceded that he did not verify who occupied the premises. No revenue records, bills, or statements of neighbours were produced to establish ownership or possession on the house. Without proof of exclusive possession, recovery from the premises cannot be treated as incriminating.”
Contradictions and Evidentiary Infirmities
It would be instructive to note that the Division Bench hastens to add in para 75 noting succinctly that,
“The contradictions between the depositions of panch witnesses Krunalkumar (PW-7) and Altaf Husenbhai (PW-8), and Investigating Officer (PW-15); the absence of proof regarding the ownership of the house; the lack of a proper chain of custody of seized items; and the medical evidence negating the presence of semen on the child victim, casts grave doubt on the genuineness of the recoveries. The attempt of the prosecution to rely on the FSL report despite these grave infirmities is unacceptable. Since the seizures itself were tainted and the ownership of the house remains unproven, the FSL results hold no evidentiary value. The trial Court and High Court overlooked these critical flaws and the possibility of planting evidence, thereby committing serious error in recording the conviction.”
Unreliable Prosecution Narrative
It is worth noting that the Division Bench notes in para 76 that,
“Thus, we are convinced that the entire story of the prosecution wherein it has been claimed that the accused-appellant was seen throwing out the child victim in a denuded condition after committing forcible sexual assault upon her is not established by any credible or reliable evidence. Rather, we find the conduct of the complainant, Nazir Mohammed (PW1), Journalist Vivekbhai (PW-2), witnesses of last seen together circumstance, Arifkhan (PW-3) and Shahejadkhan (PW-4) and also of the concerned Investigating Officers (PW-14 and PW-15) to be highly unnatural, suspicious, full of improbabilities, and self-contradictions.”
Acquittal and Release Directions
As a corollary, the Division Bench directs and holds in para 78 that,
“Having made a thorough analysis of the evidence on record, and for the reasons stated above, we find that the impugned judgment do not stand to scrutiny. As a result, the judgment of conviction and order of sentence dated 3rd November, 2015, rendered by the trial Court and the impugned judgment dated 5th April, 2016, rendered by the High Court are hereby set aside. The appellant stands acquitted of the charges. He is in custody and shall be released forthwith, if not wanted in any other case.”
Directions on Standardized Format: The Cornerstone of the Judgment
Most significantly, the Apex Court then encapsulates in the concluding paras (81 – 90) what constitutes the cornerstone of this notable judgment postulating precisely that,
“81. Before parting with the present case, we would like to highlight that the judgments of the trial Court as well as the High Court in the instant case have indeed appended charts of witnesses and documents in their respective judgments. However, we are of the considered view that a more structured and uniform practice must be adopted to enhance the legibility of criminal judgments. Accordingly, to ensure a systematic presentation of evidence that enables efficient appreciation of the record, we issue the following directions to all trial Courts across the country. These directions aim to institutionalize a standardized format for cataloguing witnesses, documentary evidence, and material objects. This will serve to facilitate better comprehension and immediate reference for all stakeholders, including the Appellate Courts. Hence, we are passing the following directions, which shall be adhered to by all trial Courts across the country.”
82. Preparation of Tabulated Charts in All the Judgments
82.1 Mandatory Tabulated Charts
All trial Courts dealing with criminal matters shall, at the conclusion of the judgment, incorporate tabulated charts summarizing:
- Witnesses examined,
- Documents exhibited, and
- Material objects (muddamal) produced and exhibited.
82.2 Placement and Format of Charts
These charts shall form an appendix or concluding segment of the judgment and shall be prepared in a clear, structured and easily comprehensible format.
83. Standardized Chart of Witnesses
83.1 Mandatory Columns
Each criminal judgment shall contain a witness chart with at least the following columns:
- Serial Number
- Name of the Witness
- Brief Description/Role of the Witness, such as: Informant, Eye-witness, Medical Jurist/Doctor, Investigating Officer (I.O.), Panch Witness, etc.
83.2 Purpose of Witness Description
The description should be succinct but sufficient to indicate the evidentiary character of the witness. This structured presentation will allow quick reference to the nature of testimony, assist in locating the witness in the record, and minimize ambiguity.
83.3 Specimen Chart for Witnesses Examined
| Prosecution Witness No. | Name of Witness | Description |
|---|---|---|
| 1 | Mr. X | Eye-witness |
| 2 | Mr. Y | Witness of last seen circumstance |
| 3 | Ms. Z | Medical Jurist |
| 4 | Mr. A | Investigating Officer |
| 5 | Mr. B | Complainant/First Informant |
84. Standardized Chart of Exhibited Documents
84.1 Mandatory Columns
A separate chart shall be prepared for all documents exhibited during trial. This chart shall include:
- Exhibit Number;
- Description of document;
- The Witness who proved or attested the document.
84.2 Illustrative Document Descriptions
Illustratively, the description may include: FIR, complaint, panchnamas, medical certificates, FSL reports, seizure memos, site plans, dying declarations, etc.
84.3 Traceability of Proof
The requirement of specifying the witness who proved the document ensures traceability of proof and assist the Court in appreciating compliance with the Indian Evidence Act, 1872/Bharatiya Sakshya Adhiniyam, 2023.
84.4 Specimen Chart for Exhibited Documents
| Exhibit No. | Description of the Exhibit | Proved by/Attested by |
|---|---|---|
| 1 | Inquest Panchnama/Memo | PW-1 |
| 2 | Recovery Panchnama/Memo | PW-2 |
| 3 | Arrest Memo | PW-3 |
| 4 | Post-mortem Report | PW-4 |
| 5 | FSL Report | PW-5 |
85. Standardized Chart of Material Objects/Muddamals
85.1 Mandatory Columns
Whenever material objects are produced and marked as exhibits, the trial Court shall prepare a third chart with:
- Material Object (M.O.) Number;
- Description of the Object;
- Witness who proved the Object’s Relevance (e.g., weapon, clothing, tool, article seized under panchnama, etc.)
85.2 Clarity of Physical Evidence
This enables clarity regarding the physical evidence relied upon.
85.3 Specimen Chart for Material Objects/Muddamals
| Material Object No. | Description of the Exhibit | Proved by/Attested by |
|---|---|---|
| 1 | Weapon of Offence | PW-1 |
| 2 | Clothing of accused/victim | PW-2 |
| 3 | Mobile Phone/Electronic Object | PW-3 |
| 4 | Vehicle | PW-4 |
| 5 | Purse/earrings/identity card | PW-5 |
86. Special Provisions for Cases Involving Voluminous Evidence
In complex cases, such as conspiracies, economic offences or trials involving voluminous oral or documentary evidence, the list of witnesses and exhibits may be substantially long. Where the number of witnesses or documents is unusually large, the trial Court may prepare charts only for the material, relevant, and relied-upon witnesses and documents, clearly indicating that the chart is confined to such items. This ensures that the charts remain functional reference tools rather than unwieldy compilations.
87. Application to Defence Witnesses and Evidence
The aforesaid directions shall apply, mutatis mutandis, to all witnesses examined and all evidence adduced by the defence.
88. Adoption of Specimen Format and Permissible Deviations
The specimen charts provided herein shall ordinarily serve as the standard format to be followed by trial Courts across the country.
89. Observations Regarding Applicability to Civil Proceedings
While these directions are primarily intended to streamline criminal trials, we leave it open to the High Courts to consider, wherever appropriate, the adoption of similar tabulated formats in civil matters as well, particularly in cases involving voluminous documentary or oral evidence, so as to promote clarity, uniformity, and ease of reference.
90. Incorporation in High Court Rules and Compliance
The High Court may consider incorporating the above directions in their respective rules governing the procedure of trial Courts.
Registry shall forthwith transmit a copy of this judgment to the Registrar General of all the High Courts to ensure due compliance with the directions issued by this Court in paragraph Nos. 81-90 (supra).
Final Direction of the Division Bench (Para 91)
Finally, the Division Bench then concludes by holding and directing aptly in para 91 that,
“Registry shall forthwith transmit a copy of this judgment to the Registrar General of all the High Courts to ensure due compliance with the directions issued by this Court in paragraph Nos. 81-90 (supra).”
Sanjeev Sirohi, Advocate,
s/o Col (Retd) BPS Sirohi, A 82, Defence Enclave,
Sardhana Road, Kankerkhera, Meerut – 250001, Uttar Pradesh
