Historic rulings change the path of legal history when justice is at stake. This audacious claim sums up the malkiat singh vs state of punjab case nicely. The horrific act of murder is at the center of this case. The accused, Malkiat Singh, was prosecuted under section 302 of the indian penal code, which stipulates harsh penalties for anybody convicted of taking another person’s life.
Based solely on circumstantial evidence, the trial court’s conviction of Malkiat Singh resulted in a number of appeals, which eventually led to a major ruling by the Supreme Court. The legal procedure demonstrates the exacting standards of proof and sound legal reasoning needed to support a conviction for a crime this heinous, from the preliminary inquiry to the Supreme Court’s ultimate decision.
malkiat singh vs state of punjab Case Facts
- Along with Head Constable Badan Singh and other officials, Sub Inspector Banarasi Lal of the Food and Supplies Department had been posted at Smalkha Barrier on October 19, 1961. The appellant, Malkiat Singh, arrived in truck number P.N.U. 967 driven by Babu Singh, the truck cleaner. About 140 maunds, or 75 bags, of paddy, were loaded onto the vehicle.
- Since it was against the law to transport paddy, the Sub Inspector had to seize the truck and its contents. On October 18, 1961, Qimat Rai booked the consignment from Lakerkotla on behalf of Messrs Sawan Ram Chiranji Lal. The intended recipient of the paddy was Messrs Devi Dayal Brij Lal from Delhi.
- A letter addressed to the consignee, Ex. P-3, was provided by Qimat Rai. Together with a supposedly authorized letter, Malkiat Singh stated that he obtained the paddy for delivery to Delhi from the Transport Company in Malerkotla. But rather than being an official transport permit, this letter was a private correspondence between Qimat Rai and the commission agents in Delhi.
- Malkiat Singh acknowledged operating the paddy-filled truck that was stopped at the Samalkha Barrier. As the cleaner, Babu Singh affirmed his presence. All parties involved were found guilty by the trial court; however, Sawan Ram and Chiranji Lal were later found not guilty by the Additional Sessions Judge, who upheld the convictions of Babu Singh, Malkiat Singh, and Qimat Rai.
- The convictions were upheld on November 4, 1965, when the appellants’ revision petition was denied by the High Court. This ruling emphasized the legal obligations of transport providers and the tight implementation of laws against the unlawful transportation of commodities.
malkiat singh vs state of Punjab: Prior Proceedings
The Trial Court heard the case. Malkiat Singh (appellant no. 1) acknowledged the following facts during the criminal proceedings.
- He stated in his testimony that he received the paddy sacks from a transport company to deliver to Delhi.
- He said that he had received a paper from the transport business that purported to be a letter, and that if he could provide it, he would be granted permission to carry out the aforementioned paddy bag transportation. It was eventually discovered, nevertheless, that Qimat Rai was merely writing a personal letter to the commission agents in Delhi and that the letter lacked the power to transport.
All five of the accused in this case were found guilty by the Trial Court. The convictions of Sawan Ram and Chirnaji Lal were challenged, and Qimat Rai, Malkiat Singh, and Babu Singh were found guilty. The case was then appealed to the Additional Sessions Judge. Following the conviction of these three defendants, a revision plea was filed in the Punjab High Court; however, it was eventually dismissed on November 4, 1965.
Malkiat Singh and Babu Singh, the appellants in this case, filed an appeal in order to contest the High Court’s decision to dismiss the case from the Supreme Court of India.
malkiat singh vs state of punjab Issues
- Did the lower courts find that the appellants had committed any wrongs?
malkiat singh vs state of Punjab: Provisions Involved
Section 3 of the Essential Commodities Act
- The central government has the authority to regulate the production, distribution, and supply of essential commodities by Section 3 of the Essential Commodities Act. In order to ensure that vital commodities are distributed fairly, are readily available, and are produced in sufficient quantities, the government may restrict or outright forbid their manufacture, distribution, and supply under this section.
- Section 3 of the necessary goods Act was pertinent in the Malkiat Singh v. State of Punjab case because it established the legal foundation for the regulation of necessary goods, which was a crucial component of the case. The court considered whether Malkiat Singh’s acts were covered by this section, especially considering that they violated the rules the government had established to regulate necessities.
Section 7 of the Essential Commodities Act
- The Essential Commodities Act’s Section 7 describes the sanctions for breaking Section 3 instructions. It stipulates that anyone who disobeys an order issued under Section 3 faces up to seven years in prison and a fine. Furthermore, the provision allows for the seizure of the necessary item used in the offense.
- In the event that Malkiat Singh was found guilty of breaking the Essential Commodities Act, Section 7 was crucial in calculating his sentence. The court carefully examined whether the accused’s actions justified the punishments listed in this section, taking into account the seriousness of the crime and its effects on the distribution and supply of necessities.
Contentions by the Parties
Petitioner:
- The question on appeal is whether the appellants have committed an offense based on evidence found by the lower courts. Undoubtedly, the paddy came to an end at the Samalkha Barrier, which is located 32 miles away from Delhi.
- It is also undeniable that the boundary between Punjab and Delhi is, at the proper moment, approximately eighteen miles from Delhi. Thus, it is evident that in this instance, there is no paddy export from Punjab.
- At the Samalkha well, which is located inside the Punjab border, the truck carrying paddy was impounded. As a result, the Punjab Paddy (Export Control) Order of 1959’s paragraph 2(a) does not apply to exports of rice.
Respondent:
- The appellants’ attempt to transport paddy to Delhi, according to the defendant’s attorney, indicates that an attempt was made to commit the export offense.
malkiat singh vs state of punjab Judgment
- In the Malkiat Singh v. State of Punjab case, the Supreme Court thoroughly examined the pertinent legal precedents and factual issues. The appellants’ activities, according to the court, were not an attempt to commit the crime as specified by the statute, but rather only preparation.
- Legal precepts state that preparing to commit an offense is not the same as really trying to commit one. Crucially, merely preparing to commit an offense is not punishable under the essential commodities act.
- The court decided that the appellants shouldn’t have been found guilty in accordance with Section 7 of the essential commodities act because of this legal disparity.
- This part of the Act does not apply to the punishment of simple preparatory activities; rather, it relates to the specific offenses connected to the regulation and control of essential commodities.
The Supreme Court granted the appeal for these reasons. The court overturned each appellant’s fine punishment and the conviction of the appellants pursuant Section 7 of the Essential Commodities Act. In addition, the court reversed Qimat Rai’s conviction, sentencing, and forfeiture order pertaining to 75 bags of rice and truck number P.N.U 967, which had been issued by the trial magistrate. Refunds of any fines previously paid by the convicted parties were also ordered by the judgment.
In 1959, the Punjab state issued a notification that exporting paddy outside of the state, as well as attempting to do so and providing assistance, was illegal. In the 1968 case of Malkiat Singh & Anr. v. State of Punjab, the state of Punjab claimed that the defendants had attempted to export and had asked the court to punish them. In the current case, the Supreme Court must decide whether the accused person’s actions were merely preparatory to export or if they represent an attempt at export.
In its ruling, the court created a clear distinction between the two by giving definitions, justifications, and instances. It then decided that the vehicle had halted at the Samalkha Barrier and that the appellants had made preparations, but not an attempt, to export the grain. Consequently, no charges were brought against the appellants.
The Malkiat Singh v. State of Punjab case serves as an illustration of how India’s criminal code is applied correctly. Malkiat Singh and his fellow appellants were found not guilty by the Supreme Court, which underscored the need for clear legal criteria and the defense of individual rights against erroneous convictions. It reaffirms the fundamental idea that, in the context of the Essential Commodities Act, a mere plan to conduct a crime does not carry the same legal consequences as an actual effort. The court underscored the need for tangible activity beyond mere preparation to merit criminal penalties by overturning the convictions since there was no attempt to commit an offense.
This idea protects against the overreach of the law and makes sure that people aren’t unfairly punished for doing things that don’t even qualify as attempts.
With the goal of giving students the best coaching available for law entrance exams including the CLAT, AILET, and various other numerous state judiciary exams, Jyoti Judiciary Coaching, India’s Finest educational Platform, was established. Come enrol now with Jyoti Judiciary!
For any latest news, legal topics, judiciary exams notifications, patterns, etc watch Jyoti Judiciary’s YouTube channel for legal videos for any updates at https://youtube.com/@jyotijudiciarycoaching4852?si=2cwubh9d2A9urwJf
