Supreme Court issues directions for Cataloguing witnesses and documentary evidences in Criminal Trial: Manojbhai Jethabhai Parmar Case

REPORTABLE

SUPREME COURT OF INDIA
CRIMINAL APPELLATE JURISDICTION

MANOJBHAI JETHABHAI PARMAR (ROHIT) (APPELLANT(S)
VERSUS
STATE OF GUJARAT ….RESPONDENT(S)

CRIMINAL APPEAL NO(S). 2973 of 2023

Date of Judgment- 15.12.2025

HEADNOTE-

This Appeal has been preferred by the accused-appellant to the High court for assailing the judgment of the trial Court stands dismissed vide final judgment and order dated 5th April, 2016 which is assailed in this appeal by Special Leave–Trial Court observed-the prosecution proved the complete and unbroken chain of incriminating circumstances by leading unimpeachable evidence and proceeded to convict and sentence the accused-appellant. HELD-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.

IMPORTANT PARAGRAPHS-

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. 

82. Preparation of Tabulated Charts in all the judgments:

82.1 All trial Courts dealing with criminal matters shall, at the conclusion of the judgment, incorporate tabulated charts summarizing: –

       a. Witnesses examined,
       b. Documents exhibited, and
       c. Material objects (muddamal) produced and exhibited. 

82.2. 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. Each criminal judgment shall contain a witness chart with at least the following columns:
      a. Serial Number
      b. Name of the Witness
      c. Brief Description/Role of the Witness, such as: Informant, Eye-witness, Medical Jurist/Doctor,                                            Investigating Officer (I.O.), Panch Witness, etc. 

83.2. 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-

84. Standardized Chart of Exhibited Documents

84.1 A separate chart shall be prepared for all documents exhibited during trial. This chart shall
include:
a. Exhibit Number;
b. Description of document;
c. The Witness who proved or attested the
document.
84.2 Illustratively, the description may include: FIR, complaint, panchnamas, medical certificates,
FSL reports, seizure memos, site plans, dying declarations, etc. 

84.3. 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-

85. Standardized Chart of Material Objects/Muddamals
85.1 Whenever material objects are produced and marked as exhibits, the trial Court shall prepare a third chart with:

        a. Material Object (M.O.) Number;
        b. Description of the Object;

        c. Witness who proved the Object’s Relevance (e.g., weapon, clothing, tool, article seized under panchnama, etc.)

85.3.Specimen Chart for Material Objects/Muddamals-

86. Special Provisions for Cases Involving Voluminous Evidence

86.1. 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
87.1. 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

88.1. 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

89.1. 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. The High Court may consider incorporating the above directions in their respective rules governing the procedure of trial Courts.