Tuesday, March 4, 2025

Cause Shown on Pre-Cognizance Notice

 

In the Court of the Learned 17th Judicial Magistrate,

 Calcutta

 

Case No. : CNS/33/2025

 

                                                          In the matter of :-

 

Vijay Ply % Boards, a proprietorship firm having its office at DD-1, Narayanatala East, Baguihati, Kolkata – 700159, represented through its proprietor Manoj Kumar Vijayvergia;

                   _________Complainant

-      Versus –

 

Kamal Choudhary, Proprietor Design Koncept, of 2A, Banerjee Para Road, Karunamoyee, Tollygunge, Kolkata – 700041, and also at Diamond City South, Tower -3, Flat no. 10E, 58, Mahatma Gandhi Road, Karunamoyee, Tollygunge, Kolkata – 700041. .

 

                   __________Accused

 

Cause Shown on Pre-Cognizance Notice

 

The humble Petition of the above named alleged accused person Kamal Choudhary, most respectfully;

 

Sheweth as under;

 

(1)  That the Petitioner is in receipt of the Pre-Cognizance Notice, issued by the Learned Court, which states as follows;

 

“WHEREAS the Complainant has filed the instant case (Ref.: CNS/33/2025) and for which you are hereby directed to appear before this Learned Court in person on 03/03/2025 at 10:30 A.M. along with relevant documents supporting your contention as to why the cognizance should not be taken against you, by this Learned Court.”

 

Photostat Copy of the said Pre-Cognizance Notice, with the copy of the complaint made by the complainant is annexed herewith and marked as Annexure – “A”, Collectively.

  

(2)  The said Pre-Cognizance Notice has been served only with a copy of complaint made by the Complainant herein before the Learned Court. But the said Pre-Cognizance Notice doesn’t give any copy of the statements made by the Complainant and other witnesses, ever deposed by them before the Learned Court, and the Documents relied on by the Complainant. Therefore the substantial deposition of the witnesses and the documents has not ever been served on the petitioner who is the alleged accused person cited by the Complainant, herein.

 

(3)   The settled law with respect to Section 200 CrPC was as in a complaint case (private prosecution) an accused person does not come into the picture till process(summons or warrants) is issued. And process, we all understand, is issued after the judge examines the complainant, records what is known as pre-summoning evidence (PSE) & finds a prima facie case in favour of the Complainant and sufficient grounds for believing that an offence has taken place and accused has committed that offence. This is essentially a matter between the court and the Complainant. The accused has no locus standi to appear and argue before he or she is summoned in the case.Though being summoned in a criminal case – by itself – is a serious matter, this does not prejudice the accused who gets the chance to put forth his/her case after cognizance and earn an exoneration. There are several avenues for this. The accused may, for instance, challenge the summoning order in a revision petition. The accused may also apply for quashing of the case to the High Court under Section 482 Cr.P.C. Further, the accused may take his chances and argue for discharge before the same court, if the matter is not worthy of being taken to trial. This was the law; well, until now.

 

(4)   Section 223 of the BNSS (which replaces the earlier S.200 CrPC), now in force in all its glory, has added an interesting (and potentially problematic!) proviso. It reads: 

https://bharatchugh.in/wp-content/uploads/2024/07/image.png?w=870

 

 

 

 

Focus on the proviso;

 

It’s clear that – now – cognizance of an offence on a “complaint” cannot be taken by the Magistrate without giving the accused an opportunity of being heard.

 

Now, for those who arrived late, Cognisance, we all understand, connotes the process of : application of judicial mind by the court to the facts stated in a complaint or police report or information received – with a view to taking further steps.

 

It is clear that – now – the provision envisages issuance of a notice before taking of cognisance. This effectively means that for complaints under BNSS, the Judicial Magistrate must give the accused – or more appropriately the proposed accused – an opportunity of being heard prior to cognisance i.e prior to application of judicial mind.

 

Giving the accused an opportunity to be heard even before cognizance is taken was unheard-of in a criminal proceeding until now.

 

The ostensible intent appears to be to give the accused an additional opportunity to be heard & possibly to reduce chances of false implication & to allow accused persons to avoid being summoned in false criminal cases.

 

(5)  But the manner, mode and timing of this notice is not clear. There are serious doubts as to whether this notice to the proposed accused is to be issued after PSE or before. Is it to be issued the moment the complaint is received and registered, or after some basic inquiry into its merit?

 

(6)  That Hon’ble High Court of Karnatka at Bengaluru, decided in Criminal Petition No. 7526 of 2024 {Sri Basanagouda R. Patil (Yatnal), - Versus – Sri Shivananda S. Patil} vide CAV Order dated 27th day of September, 2024, by Hon’ble Mr. Justice M. Nagaprasanna, which provide clarity on the Pre Cognizance Notice to the Accused as follows;

 

(a)  Proviso to sub-section (1) of Section 223 of the BNSS mandates  that a Magistrate while taking cognizance of an offence, on a  complaint, shall examine upon oath, the complainant and the  witnesses present if any and reduce it into writing. The proviso further mandates that no cognizance of an offence shall be taken by the Magistrate without giving an opportunity to the accused of being heard. Section 227 of the BNSS deals with issuance of process which is akin to Section 204 of the Cr.P.C. This stage is yet to arrive in the case at hand.

 

(b)  The obfuscation generated in the case at hand is with regard to interpretation of Section 223 of the BNSS, as to whether on presentation of the complaint, notice should be issued to the accused, without recording sworn statement of the complainant, or notice should be issued to the accused after recording the sworn statement, as the mandate of the statute is, while taking cognizance of an offence the complainant shall be examined on oath. The proviso mandates that no cognizance of an offence shall be taken by the Magistrate without giving the accused an opportunity of being heard.  

 

(c)  To steer clear the obfuscation, it is necessary to notice the language deployed therein. The Magistrate while taking cognizance of an offence should have with him the statement on oath of the complainant and if any witnesses are present their statements.  The taking of cognizance under Section 223 of the BNSS would come after the recording of the sworn statement, at that juncture a notice is required to be sent to the accused, as the proviso mandates grant of an opportunity of being heard.  

 

(d)  Therefore, the procedural drill would be this way:  

 

A complaint is presented before the Magistrate under Section 223 of the BNSS; on presentation of the complaint, it would be the duty of the Magistrate / concerned Court to examine the complainant on oath, which would be his sworn statement and examine the witnesses present if any, and the substance of such  examination should be reduced into writing. The question of taking  of cognizance would not arise at this juncture. The magistrate has to, in terms of the proviso, issue a notice to the accused who is given an opportunity of being heard. Therefore, notice shall be issued to the accused at that stage and after hearing the accused, take cognizance and regulate its procedure thereafter.

 

(e)  The proviso indicates that an accused should have an opportunity of being heard. Opportunity of being heard would not mean an empty formality. Therefore, the notice that is sent to the  accused in terms of proviso to sub-section (1) of Section 223 of the  BNSS shall append to it the complaint; the sworn statement;  statement of witnesses if any, for the accused to appear and  submit his case before taking of cognizance. In the considered view of this Court, it is the clear purport of Section 223 of BNSS, 2023.  

 

(f)   The moment complaint is filed, notice is issued to the accused. This procedure is erroneous.

 

Photostat Copy of CAV Order dated 27th day of September, 2024, by Hon’ble Mr. Justice M. Nagaprasanna, Hon’ble High Court of Karnatka at Bengaluru, decided in Criminal Petition No. 7526 of 2024 {Sri Basanagouda R. Patil (Yatnal), - Versus – Sri Shivananda S. Patil}, is annexed herewith and marked as Annexure – “B”.

 

(7)  That in views derived from the said CAV Order dated 27th day of September, 2024, by Hon’ble Mr. Justice M. Nagaprasanna, Hon’ble High Court of Karnatka at Bengaluru, decided in Criminal Petition No. 7526 of 2024 {Sri Basanagouda R. Patil (Yatnal), - Versus – Sri Shivananda S. Patil}, the Petitioner is entitled to get copy of the sworn statement;  statement of witnesses if any, in the present complaint case, with documents relied on by the complainant or annexed ever with the petition of complaint, to the Petitioner to appear and  submit his case before taking of cognizance, in terms of the prescribed provisions enshrined under the clear purport of Section 223 of BNSS, 2023. Therefore in absence of any copy of the sworn statement; statement of witnesses if any, in the present complaint case, the petitioner is not able to place his case before the Learned Court. The Petitioner reserve his rights to answer or reply on the Complaint case lodged by the Complainant, while the Petitioner will receive the copy of the sworn statement; statement of witnesses if any, in the present complaint case, with documents relied on by the complainant or annexed ever with the petition of Complaint.

 

(8)  That unless, the Learned Court direct the Bench Clerk to give the copy of the sworn statement;  statement of witnesses if any, in the present complaint case, with documents relied on by the complainant or annexed ever with the petition of Complaint, the Petitioner is highly prejudice and suffer with irreparable loss and injury thereof.

 

 

 

 

 

(9)  That the preponderance of the balance of convenience and inconveniences are favouring the Petitioner, who is an alleged accused person cited by the Complainant, in the present Complaint proceeding under Section 223 of BNSS, 2023.

 

(10)              That this application is made bonafide and in the interest of administration of Justice.

 

It is therefore prayed that your Honour would graciously be pleased to allow this application and to direct the Bench Clerk to give the copy of the sworn statement;  statement of witnesses if any, in the present complaint case, with documents relied on by the complainant or annexed ever with the petition of Complaint, to the Petitioner herein, in the interest of administration of Justice, and or to pass such other necessary order or orders as your Honour may deem, fit, and proper for the end of Justice.

 

And for this act of kindness, the Petitioner as in duty bound shall ever pray.

 

Verification

 

I Kamal Choudhary, being the alleged accused person in the present Complaint case lodged by the Complainant, made this application on receipt of the Pre-Cognizance Notice. I am well conversant and acquainted with the material facts. I Verify and sign this petition on 17th day of March’ 2025, at the Bankshall Court Premises.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Affidavit

I, Kamal Choudhary, Proprietor Design Koncept, aged about _____years, by faith Hindu, by Occupation Business, having office at Premises being no. 2A, Banerjee Para Road, Karunamoyee, Tollygunge, Kolkata – 700041, and also at Diamond City South, Tower -3, Flat no. 10E, 58, Mahatma Gandhi Road, Karunamoyee, Tollygunge, Kolkata – 700041, do hereby solemnly affirm and says as follows ;

1.   That I being the Petitioner named above in the present application on receipt of the Pre-Cognizance Notice. I am conversant and acquainted with the material facts. I am Competent to swear this affidavit.

 

2.   That the content of paragraph no. 1, & 2, are true to my knowledge and belief and the rests are my humble submissions before the Learned Court.

That the above statements are true to my knowledge and belief.

 

 

 

DEPONENT

Identified by me,

 

 

Advocate

Prepared in my Chamber,

 

 

 

Advocate

Date : 17th day of March’ 2025;

Place : Bankshall Court, Kolkata

 

N O T A R Y

 

 

 

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