S.Veeramani vs State Of Tamilnadu on 18 February, 2026

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    Madras High Court

    S.Veeramani vs State Of Tamilnadu on 18 February, 2026

    Author: Mohammed Shaffiq

    Bench: Mohammed Shaffiq

                                                                                            Crl.R.C(MD)No.292 of 2026
    
                              BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
    
                                                      DATED: 18.02.2026
    
                                                              CORAM
    
                                THE HONOURABLE MR.JUSTICE MOHAMMED SHAFFIQ
    
                                               CRL.R.C.(MD)No.292 of 2026
                                                           and
                                               Crl.M.P.(MD).No.3681 of 2026
    
                         S.Veeramani                                                        ... Petitioner
                                                                   vs.
                         State of Tamilnadu,
                         Rep By Inspector Of Police,
                         Thevaram,
                         Police Station,
                         Theni District.
                         (Crime No.13/2018)                                                        ... Respondent
    
                         PRAYER: Criminal Revision Petition is filed under Section 438 r/w 442
                         of BNSS, 2023, to call for the records pertaining to the order passed in
                         S.C. No. 18 of 2019 dated 19.06.2024 on the file of the Assistant
                         Sessions Court cum Chief Judicial Magistrate, Theni confirmed by the
                         Additional District Judge (FTC), Theni in Crl.A. No. 110 of 2024 dated
                         07.11.2024 and set aside the same.
    
    
                                       For Petitioner         : Mr.M.Karunanithi
    
                                       For Respondent         : Mr.P.Kottaichamy
                                                                Government Advocate
    
    
    
    
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                                                                                                 Crl.R.C(MD)No.292 of 2026
                                                                  ORDER
    

    The present Criminal Revision Petition has been filed challenging

    the judgment of Additional District Judge (FTC), Theni in Crl.A. No. 110

    SPONSORED

    of 2024 dated 07.11.2024, whereby, the appeal was dismissed summarily

    on the premise of non-prosecution. Relevant portion of judgment reads

    as under:

    “Appellant called absent. No representation by
    Advocate, sufficient time already given. Hence this Appeal
    is dismissed for non prosecution.”

    2. The short question that arises for consideration in the present

    revision is as to whether it is open to Appellate Court to dismiss the

    appeal summarily on the premise that appellant is called absent and is not

    represented by any counsel. The above question is no longer res integra

    and stands resolved by a series of judgments of the Supreme Court and

    other High Courts.

    3. However, before I proceed to answer the above question, it may

    be relevant to give a brief overview of the case. The defacto complainant

    Gubendran/PW.1 is brother of the injured witness, Arivu @

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    Crl.R.C(MD)No.292 of 2026
    Karuppanan/PW.2. Case of prosecution is that petitioner/accused

    S.Veeramani and defacto complainant attended a funeral of Periyapandi

    in their village. At that time, a wordy quarrel arose between

    petitioner/accused and defacto complainant’s sister’s husband with regard

    dispute over money. Immediately, Arivu @ Karuppanan/PW.2 intervened

    and abused petitioner/accused. During the last rites of Periyapandi, when

    Arivu @ Karuppanan/PW.2 was standing near burial ground, accused

    arrived at the spot, abused Arivu @ Karuppanan/PW.2 and stabbed him

    on the left side of his stomach and fled from the scene of occurrence. On

    the basis of complaint given by P.W.1, FIR was registered in Crime No.

    13 of 2018 for offences under Section 294(b) and 307 of IPC. On

    completion of investigation, charge sheet was filed in P.R.C.No.09 of

    2018 and the case was committed and numbered in S.C.No.18 of 2019 on

    the file of Assistant Sessions Court cum Chief Judicial Magistrate, Theni.

    4. Assistant Sessions Court cum Chief Judicial Magistrate, Theni,

    by order dated 19.06.2024 passed in S.C.No.18 of 2019, acquitted the

    petitioner of offence under Section 294(b) of IPC and convicted for

    offence under Section 307 of IPC and sentenced him to undergo four

    years rigorous imprisonment and to pay a fine of Rs.1000/-, in default to

    undergo one month simple imprisonment.

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    Crl.R.C(MD)No.292 of 2026

    4.1. Aggrieved, petitioner filed an appeal before Additional

    District Judge (FTC), Theni in Crl.A.No.110 of 2024. However, appeal

    came to be dismissed summarily by merely recording ”Appellant called

    absent. No representation by Advocate, sufficient time already given.

    Hence this Appeal is dismissed for non prosecution”.

    4.2. It is against the above order of summary dismissal by

    Appellate Court, the present revision has been filed on the premise that

    once the Appellate Court has admitted the appeal, it ought to be decided

    on merits and it is impermissible for the Appellate Court to dismiss the

    appeal for non-prosecution or for non-appearance of appellant or his

    counsel.

    5. The above question, as stated supra, is no longer res integra and

    stands resolved by the judgment of three Judges Bench of the Supreme

    Court in Bani Singh and others Vs. State of U.P. reported in (1996) 4

    SCC 720. The Supreme Court in Bani Singh‘s case while dealing with

    the question as to whether it is permissible to dismiss an appeal for non-

    prosecution, overruled the earlier decision in Ram Naresh Yadav Vs.

    State of Bihar reported in AIR 1987 SC 1500. In Ram Naresh Yadav’s

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    Crl.R.C(MD)No.292 of 2026
    case, it was found that the Court can dismiss the appeal for non-

    prosecution and enforce disciplinary action against the erring Advocate

    or refer the matter to Bar Council. In Bani Singh‘s case, it was held that

    the decision in Ram Naresh Yadav‘s case was rendered without noticing

    the earlier decision in Shyam Deo Pandey and others Vs. State of Bihar

    reported in AIR 1971 SC 1606, wherein, it was held that once the

    Appellate Court had admitted the appeal, it must be heard on merits and

    Appellate Court cannot dismiss the appeal for non-prosecution or for

    non-appearance of the appellant or his counsel. Relevant portion of the

    judgment in Shyam Deo Pandey‘s case is extracted hereunder:

    ”19. A reading of Section 423 makes it clear that a criminal
    appeal cannot be dismissed for default of appearance of the
    appellants or their counsel. The Court has either to adjourn the
    hearing of the appeal in order to enable them to appear or it
    should consider the appeal on merits and pass final orders. The
    consideration of the appeal on merits at the stage of final
    hearing and to arrive at a decision on merits so as to pass final
    orders will not be possible unless the reasoning and findings
    recorded in the judgment under appeal are tested in the light of
    the record of the case. After the records are before the Court
    and the appeal is set down for hearing, it is essential that the
    appellate court should: (a) peruse such record; (b) hear the
    appellant or his pleader, if he appears, and (c) hear the public
    prosecutor, if he appears. After complying with these
    requirements, the appellate court has full power to pass any of
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    Crl.R.C(MD)No.292 of 2026
    the orders mentioned in the section. It is to be noted that if the
    appellant or his pleader is not present or if the public
    prosecutor is not present it is not obligatory on the appellate
    court to postpone the hearing of the appeal. If the appellant or
    his counsel or the public prosecutor, or both, are not present,
    the appellate court has jurisdiction to proceed with the
    disposal of the appeal; but that disposal must be after the
    appellate court has considered the appeal on merits.”

    (emphasis supplied)

    6. Thus divergent views were expressed by the Supreme Court in

    Ram Naresh Yadav and Shyam Deo Pandey. Divergence of opinion on

    the above aspect was resolved by the Supreme Court in Bani Singh’s

    case, wherein, the Supreme Court overruled the decision in Ram Naresh

    Yadav‘s case and approved the law laid down in Shyam Deo Pandey’s

    case. Relevant portion of the said decision is extracted hereunder:

    ”14. We have carefully considered the view expressed in
    the said two decisions of this Court and, we may state that
    the view taken in Shyam Deo case [(1971) 1 SCC 855 : 1971
    SCC (Cri) 353 : AIR 1971 SC 1606] appears to be sound
    except for a minor clarification which we consider necessary
    to mention. The plain language of Section 385 makes it clear
    that if the appellate court does not consider the appeal fit for
    summary dismissal, it ‘must’ call for the record and Section
    386
    mandates that after the record is received, the appellate
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    Crl.R.C(MD)No.292 of 2026
    court may dispose of the appeal after hearing the accused or
    his counsel. Therefore, the plain language of Sections
    385-386 does not contemplate dismissal of the appeal for
    non-prosecution simpliciter. On the contrary, the Code
    envisages disposal of the appeal on merits after perusal and
    scrutiny of the record. The law clearly expects the appellate
    court to dispose of the appeal on merits, not merely by
    perusing the reasoning of the trial court in the judgment, but
    by cross-checking the reasoning with the evidence on record
    with a view to satisfying itself that the reasoning and
    findings recorded by the trial court are consistent with the
    material on record. The law, therefore, does not envisage the
    dismissal of the appeal for default or non-prosecution but
    only contemplates disposal on merits after perusal of the
    record. Therefore, with respect, we find it difficult to agree
    with the suggestion in Ram Naresh Yadav case [AIR 1987 SC
    1500 : 1987 Cri LJ 1856] that if the appellant or his pleader
    is not present, the proper course would be to dismiss an
    appeal for non-prosecution.”

    7. I also find support for the above position in the following

    judgments of the Supreme Court:

    a) K.Muruganandam and others Vs. State in Criminal Appeal No.

    809 of 2021 dated 12.08.2021:

    The Supreme Court found that if the accused does not appear

    through counsel appointed by him/her, the Court is obliged to proceed
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    Crl.R.C(MD)No.292 of 2026
    with the hearing of the case only after appointing an amicus curiae.

    Relevant portion of judgment is extracted hereunder:

    ”8. It is well settled that if the accused does not
    appear through counsel appointed by him/her, the Court is
    obliged to proceed with the hearing of the case only after
    appointing an amicus curiae, but cannot dismiss the appeal
    merely because of non-representation or default of the
    advocate for the accused (see Kabira vs. State of Uttar
    Pradesh
    and Mohd. Sukur Ali vs. State of Assam).”

    b) Shankar Vs. The State of Maharashtra in Criminal Appeal

    No.1106 of 2019 dated 23.07.2019:

    It was reiterated that once appeal against conviction is admitted, it

    is duty of Appellate Court either to appoint an Advocate as amicus curiae

    or to nominate a counsel through Legal Services Authority and hear the

    matter on merits and then dispose of the appeal. Relevant portion of

    judgment is extracted hereunder:

    ”5. When the accused has preferred the appeal against
    the conviction, the appeal can be disposed of on merits only
    after hearing the appellant or his counsel. When there was no
    representation for the appellant, in our considered view, the
    High Court ought not to have disposed of the case on merits.
    It was held in 2005 (11) SCC 185 titled Mangat Singh vs.
    State of Punjab
    that where the advocate for the appellant is
    absent on the date of hearing, the Court shall either appoint
    an amicus curiae and then decide the appeal. Once the
    appeal against the conviction is admitted, it is the duty of the
    Appellate Court either to appoint an advocate as amicus
    curiae or to nominate a counsel through Legal Services

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    Crl.R.C(MD)No.292 of 2026
    Authority and hear the matter on merits and then dispose of
    the appeal. When the appellant was not represented by the
    advocate, in our view, the High Court ought not to have
    decided the matter on merits and the impugned order is liable
    to be set aside and the matter is remitted back to the High
    Court. The High Court shall restore the Criminal Appeal No.
    296 of 2014 and afford sufficient opportunity to the appellant
    and proceed with the matter in accordance with law. In case,
    if the appellant is still not represented, we request the High
    Court to nominate a counsel for the appellant through the
    Legal Services Authority and proceed with the matter.”

    8. From the above discussion, it leaves no room for any doubt that

    it is impermissible for an Appellate Court to dismiss for non-prosecution

    a criminal appeal filed against conviction on the premise that appellant is

    called absent or is not represented by a counsel. In view thereof, this

    Court has no hesitation in setting aside the judgment passed in the

    appeal. Accordingly, the judgment passed by Additional District Judge

    (FTC), Theni in Crl.A.No.110 of 2024 dated 07.11.2024 is set aside and

    the matter stands remanded to the Additional District Judge (FTC),

    Theni, who shall decide the appeal on merits. It is made clear that if for

    any reason, the appellant is not represented by counsel, appellant may

    request the Additional District Judge (FTC), Theni to nominate a counsel

    through Legal Services Authority and thereafter, proceed with the matter.

    9. It is submitted by learned counsel for petitioner that petitioner

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    Crl.R.C(MD)No.292 of 2026
    was on bail during pendency of appeal before the Additional District

    Judge (FTC), Theni. However, he is presently confined in Central Prison,

    Madurai and thus prayed for grant of bail. Learned Additional Public

    Prosecutor would submit that it is necessary that petitioner co-operates in

    proceedings before the Appellate Court, which was agreed to by learned

    counsel for petitioner.

    10. In the circumstances, this Court is of the view that since

    petitioner was on bail during pendency of appeal, he shall be enlarged on

    bail subject to the following conditions:

    i) Petitioner shall execute a bond for a sum of Rs.10,000/- (Rupees

    Ten Thousand only) with two sureties each for a like sum to the

    satisfaction of Judicial Magistrate, Bodinayackanur;

    ii) Petitioner and sureties shall affix their photographs and Left

    Thumb Impression in the bond and the above said Court may obtain a

    copy of their Aadhaar card or Bank pass Book to ensure their identity;

    iii) Petitioner shall appear and sign before Judicial Magistrate,

    Bodinayackanur, on the first working day of every month at 10.30 a.m.,

    until the disposal of appeal;

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    iv) In case, petitioner is not able to appear before the said Court on

    any day, he shall make arrangements to file an application under Section

    317 Cr.P.C. (corresponding to 355 B.N.S.S) and shall appear before the

    said Court on any other day in lieu of the date of his absence, as directed

    by the said Court.

    11. With the above observations, this Criminal Revision Case

    stands disposed of. Consequently, connected miscellaneous petition is

    closed.

                         Index              :Yes / No                                                    18.02.2026
                         Internet           :Yes / No
                         NCC                :Yes / No
                         rgm
    
                         Note:
                         Registry is directed to mark a copy of this
                         order to Central Prison, Madurai through
                         mail forthwith.
    
    
    
    
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                                                                                            Crl.R.C(MD)No.292 of 2026
                         To
    
                         1.The Judicial Magistrate, Bodinayackanur
    
    

    2.The Assistant Sessions Court cum Chief Judicial Magistrate, Theni

    3. The Additional District Judge (FTC), Theni

    4.The Inspector of Police,
    Thevaram,
    Police Station,
    Theni District.

    (Crime No.13/2018)

    5. The Additional Public Prosecutor,
    Madurai Bench of Madras High Court,
    Madurai.

    6. The Central Prison,
    Madurai.

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    Crl.R.C(MD)No.292 of 2026

    MOHAMMED SHAFFIQ, J.

    rgm

    CRL.R.C.(MD)No.292 of 2026
    and
    Crl.M.P.(MD).No.3681 of 2026

    18.02.2026

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