Introduction
In the case titled Mamman Khan v. State of Haryana (SLP [Crl.] No. 18089/2024), the Supreme Court of India issued an order on December 19, 2024, staying further proceedings in Sessions Case No. 478/2024, pending before the Additional Sessions Judge, Nuh, Haryana. This article provides an in-depth analysis of the order and its implications, referencing the context and procedural aspects involved.
Background of the Case
The petitioner, Mamman Khan, sought relief against an order of the High Court of Punjab and Haryana dated December 12, 2024, in CRM-M No. 61516/2024. The High Court’s decision, which is not detailed in the order, seemingly affected the petitioner adversely, leading to the filing of this Special Leave Petition (SLP) under Article 136 of the Constitution.
Legal Framework
The proceedings in this case touch upon several procedural and substantive legal aspects:
- Article 136 of the Constitution of India: This provision empowers the Supreme Court to grant special leave to appeal against judgments or orders of any court or tribunal in India, except military tribunals.
- Section II-B (Classification of Cases): While the specific classification of this case under Section II-B is unclear from the order, it generally pertains to criminal matters requiring judicial review.
- Interim Relief and Stay of Proceedings: The Supreme Court’s power to grant interim relief, such as staying trial court proceedings, is instrumental in preventing irreparable harm or miscarriage of justice pending a final decision.
Analysis of the Supreme Court’s Order
The order issued by the bench comprising Hon’ble Justices J.B. Pardiwala and R. Mahadevan provides significant procedural directives:
- Hearing of the Counsel: The bench recorded that the senior counsel for the petitioner, Dr. S. Muralidhar, was heard. This indicates the court’s openness to the petitioner’s contentions at the preliminary stage.
- Exemption from Filing Certified Copy: Recognizing procedural constraints, the court allowed the petitioner’s application for exemption from filing a certified copy of the impugned High Court order. This reflects a pragmatic approach, prioritizing substance over procedural formalities.
- Notice Issued with Specific Directives: The court directed that notice be served on the State of Haryana’s Standing Counsel, with the matter being returnable on January 10, 2025. This procedural clarity ensures the respondent’s adequate representation in subsequent hearings.
- Stay of Proceedings: The interim stay granted on proceedings in Sessions Case No. 478/2024 underscores the court’s concern about potential prejudicial actions against the petitioner in the interim period.
Implications of the Order
- Judicial Intervention in Criminal Trials: By staying the trial court proceedings, the Supreme Court has intervened to potentially rectify or evaluate any miscarriage of justice that may have arisen from the High Court’s decision.
- Precedential Value: Though an interim order, this decision highlights the court’s readiness to ensure procedural fairness and protect the rights of litigants.
- Impact on Lower Court Proceedings: The stay effectively pauses the trial’s progress, which might delay justice but also safeguards against irreversible outcomes during the pendency of the SLP.
Conclusion
The Supreme Court’s interim order in Mamman Khan v. State of Haryana reflects its pivotal role in balancing judicial efficiency with the protection of individual rights. By granting a stay on the trial proceedings, the court has ensured that substantive justice takes precedence over procedural rigidity.
This case underscores the importance of the judiciary in acting as a custodian of justice, especially in criminal matters where the stakes are particularly high.
References
- Constitution of India, Article 136.
- Supreme Court of India, Order dated December 19, 2024, in SLP [Crl.] No. 18089/2024.
- High Court of Punjab & Haryana, Order dated December 12, 2024, in CRM-M No. 61516/2024 (Referenced but not annexed).