Introduction 

• This is a landmark judgment where the Court laid down the law on relevancy of judgments. 
• The Judgment was delivered by a 3 judge Bench of Supreme Court consisting of Justice MB Shah, Justice Bisheshwar Prasad Singh and Justice HK Sema. 

Facts   

• The appellant filed a petition to quash criminal proceedings against them, which was rejected by the Kerala High Court, leading to this appeal. 
• The case originated from a February 1988 news item published by Madhavan about a tribal girl being raped, which led to Madhavan's arrest. 
• Madhavan alleged he was assaulted by police after his arrest, filed an FIR against police officers, and was later granted bail by the Magistrate. 
• When investigation into Madhavan's complaint against police showed no progress, the case was eventually transferred to the CBI by the Supreme Court, which also awarded Madhavan compensation of Rs.10,000. 
• The CBI filed charges against 12 accused (including the appellant) for various offenses under Indian Penal Code, 1860 (IPC) sections 324, 341, 342, 357, 219, and 166. 
• The appellant and others argued that the CBI's report was filed beyond the period of limitation under Section 468 Criminal Procedure Code, 1973 (CrPC), but this objection was ultimately unsuccessful. 
• Madhavan had also filed a civil suit for damages against the appellant, which was initially dismissed by the trial court but later the High Court set aside that judgment and remanded the case back to the trial court. 
• Currently, both the criminal prosecution and civil suit for damages are pending at the trial stage. 
• The appellant argues that based on precedents (especially V.M. Shah v. State of Maharashtra), when civil courts make findings contrary to criminal proceedings, the civil court findings should supersede the criminal court findings. 

Issues Involved  

• Whether judgment of civil proceeding is binding on the criminal proceeding, or vice versa? 

Observations 

• The Court laid down the following points with regard to relevancy of judgments: 
  • the previous judgment which is final can be relied upon as provided under Sections 40 to 43 of the Indian Evidence Act, 1872 (IEA). 
  • in civil suits between the same parties, principle of res-judicata may apply. 
  • in a criminal case, Section 300 of CrPC makes provision that once a person is convicted or acquitted, he may not be tried again for the same offence if the conditions mentioned therein are satisfied; 
  • if the criminal case and the civil proceedings are for the same cause, judgment of the civil Court would be relevant if conditions of any of the Sections 40 to 43 are satisfied, but it cannot be said that the same would be conclusive except as provided in Section 41. Section 41 provides which judgment would be conclusive proof of what is stated therein. 
• The Court held that the Constitution Bench held in the case of M.S. Sheriff v. State of Madras (1954) that no hard and fast rule can be laid down regarding precedence between civil and criminal proceedings, and the possibility of conflicting decisions is not a relevant consideration. 
  • The law laid down expressly refrains from making the decision of one court binding on another except for limited purposes such as sentence or damages. 
• Thus, the Court held that in each case the Court must first determine whether a previous judgment is relevant, and if so, to what extent it may be binding or conclusive regarding matters decided therein. 

Conclusion 

• The Court in this case enunciated that relevancy of judgment is provided under Section 40 to 43 of IEA. 
• The Court disagreed with the view that decision of one court will be binding on the other.