Within the context of the landmark criminal appeal known as Ayyub Ali v. State of Uttar Pradesh & Others, the Supreme Court addressed a fundamental procedural failure that occurred in a case that was suspected of being an honor killing.
An incorrect categorization of a murder case under a lower charge was rectified by the Court, and the Court also instructed the appropriate legal procedures to be followed.
The judgment, which was handed down on April 17, 2025, demonstrates the severe concern that the Court has over the potential for judicial discretion during the stage of framing charges, as well as the wider ramifications for justice in circumstances that are particularly sensitive.
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Historical context and the facts of the case
The case was brought up by Ayyub Ali, the father of the dead individual, Ziyahur Rahman (also known as Ziyahul or Ziaul Rahman), who was 26 years old at the time of his death and occurred under circumstances that were both suspicious and cruel.
The dead individual was found to have had fourteen antemortem injuries, including repeated hits to the head that were delivered by sticks and rods, as stated in the postmortem report.
Shock and haemorrhage owing to significant internal bleeding and dural hematoma under the parietal and frontal skull bones were determined to be the causes of death based on the findings of the investigation.
In his argument, Ayyub Ali said that the death was not the product of a fight or an accident, but rather a clear example of honor killing, and that the accused acted with the aim of committing murder.
Nevertheless, the accused was merely prosecuted under Section 304 of the Indian Penal Code, which deals with culpable homicide that does not equal to murder. This was the case with both the investigating officer and the trial court.
The application that Ayyub Ali submitted for the filing of charges under Section 302 of the Indian Penal Code in conjunction with Section 34 of the same code was rejected by the trial court, and the High Court followed up and supported the decision.
Concerns of the Supreme Court Regarding Legal Matters and Observations
The primary question that was brought before the Supreme Court was whether or not the charge ought to have been framed under Section 302 (murder) rather than Section 304 (culpable homicide not amounting to murder).
After reviewing the postmortem report and other evidence, the court came to the conclusion that the trial court had made an incorrect assumption when it found that the case did not merit a murder charge.
This was due to the fact that the weapons used in the incident were sticks and rods, rather than guns or sharp-edged weapons.
To underline that at the stage of framing charges, courts are only needed to determine whether a prima facie case exists, and not to undertake a full-fledged review of evidence, the Supreme Court relied on its earlier ruling in Ghulam Hassan Beigh v. Mohd. Maqbool Magrey.
This decision was made in response to the fact that the Supreme Court had previously ruled in that case. The court decided that the trial court had made a significant mistake when it dismissed the possibility of murder purely on the basis of the kind of weapons that were employed during the crime.
The court highlighted that the determination of whether a case comes under Section 302 or Section 304 should be deferred until the last stage of the trial, following the thorough evaluation of both oral and documented evidence.
The process of justice is hampered by premature judgments that are constructed on the basis of selective reading of the postmortem report, which may also damage the prosecution from the beginning.
Supreme Court directives and instructions
The Supreme Court issued an order that new charges be brought against the accused under Section 302 read with Section 34 of the Indian Penal Code.
This decision was issued after the Supreme Court overturned the rulings of the trial court and the High Court. However, the court made it clear that its remarks were solely for the purpose of charge formulation and not on the merits of the case. The court then instructed the trial to continue in accordance with the aforementioned manner.
The court also ordered the state of Uttar Pradesh to appoint a Special Prosecutor in consultation with the individual who filed the complaint, Ayyub Ali, because of the sensitive nature of the case and the observed deficiencies in the investigation.
It is required that this appointment be finished within a period of six weeks from the date of the order, and the court must be informed of compliance with this appointment.
In addition, the court allowed the accused to move bail petitions in light of the additional allegations that were brought against them. This means that the accused person will not be brought into jail until the bail petitions have been decided.
Regarding the Importance of the Decision
The decision of the Supreme Court was a reaffirmation of the essential concept that judicial discretion in criminal proceedings must be utilized with proper caution, especially during the vital stage of charge formation.
A reminder of the role that the court plays in ensuring that justice is not watered down as a result of procedural neglect is provided by the consistent position that the Court takes against the misclassification of charges.
Additionally, this case highlights the ongoing issue of honor murders as well as the obligation of the court system to address these homicides with the right level of gravity.
In circumstances when emotions, prejudice, or local influence may obstruct fair trial procedures, the Court proved its commitment to impartial and efficient prosecution by ordering the appointment of a Special Prosecutor. This was done in order to ensure that the cases were handled in a straightforward manner.
It is clear that the Supreme Court exercises a careful monitoring over the administration of criminal justice, as shown by the verdict in the case of Ayyub Ali v. State of Uttar Pradesh. It reaffirms the need of trial judges making effective use of their brains throughout the process of charge formulation, particularly in situations that include serious charges such as murder.
The Court has delivered a clear message that procedural shortcuts or casual assessments cannot replace appropriate legal procedure, especially in situations that may include aspects of honor-based violence. This message was conveyed by the Court’s decision to categorize the offense properly under Section 302 of the Indian Penal Code.
