Limited Factual Review Under Section 103 CrPC Can Be Exercised By High Courts

Name of the Case

K.N. Nagarajappa v. H. Narasimha Reddy

Key Takeaways

• A High Court’s judgment allowing second appeal was challenged on the ground of it being out of jurisdiction of the Court.
• The Supreme Court observed that when the lower Court while giving a decision excludes important evidence, the High court has the power to interfere.
• The High Court has been empowered under Section 103 of CrPC and several judgments on what is the scope and extent of powers of the High Court in case of irrationality and to prevent injustice.

Claims of Appellants

• The appellants argued that the High Court’s competence is confined to only examining serious legal problems.
• They claimed that the court proceeded to consider the evidence and disagreed with the findings of the first appellate court, which is the final court of facts.

Referred Cases

Municipal Committee, Hoshiarpur v. Punjab State Electricity Board:

• The factual findings made by the lower courts were tainted by a lack of examination of pertinent evidence or an incorrect approach to the case.
• A finding which ignores material evidence or excludes it and does not contain logic for the same then it would be infirm in the eyes of law.

Narayan Sitaramji Badwaik (Dead) Through Lrs. v. Bisaram:

• The High Courts are given the power under Section 103 to prevent injustice when conclusions are made based on erroneous appreciation of facts and not considering evidence that would be important for the case.

Court’s Observation

Section 103 of CrPC gives High Courts the power to exercise limited factual review.A High Court’s authority under Section 100 is derived from the way it frames a serious question of law.

It provides that in any second appeal, the HC may, determine any issue necessary for the disposal of the appeal that has not been determined by the lower Appellate Court or both by the Court of First Instance and the Lower Appellate Court or has been wrongly determined by such Court as a result of a decision on such question of law under Section 100.

The rule of law that the High Court cannot interfere with lower Court’s findings or concurrent factual conclusions unless there is a substantial question of law is subject to the two limitations.

If the factual findings are manifestly erroneous or offend the Court’s conscience; in other words, it defies logic that interference would be permissible given the facts on the record.

In the limited circumstances laid out in Section 103 CPC, the findings of fact may be called into question and overturned.

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