Actual Article
Article 134: Appellate jurisdiction of Supreme Court in regard to criminal matters
- Appellate Jurisdiction in Criminal Matters:
- An appeal shall lie to the Supreme Court from any judgment, final order, or sentence in a criminal proceeding of a High Court in the following situations:
- a) If the High Court has, on appeal, reversed an order of acquittal of an accused person and sentenced him to death.
- b) If the High Court has withdrawn for trial before itself any case from any court subordinate to its authority and has in such trial convicted the accused person and sentenced him to death.
- c) If the High Court certifies under Article 134A that the case is a fit one for appeal to the Supreme Court.
- Conditions for Appeals:
- Parliament may by law confer on the Supreme Court any further powers to entertain and hear appeals from any judgment, final order, or sentence in a criminal proceeding of a High Court in the territory of India subject to such conditions and limitations as may be specified in such law.
- Special Leave to Appeal:
- Nothing in this article shall affect the powers of the Supreme Court to grant special leave to appeal under Article 136.
UPSC Notes for Article 134
Explanation:
- Appellate Jurisdiction in Criminal Matters:
- The Supreme Court has appellate jurisdiction over criminal matters in specific cases where the High Court has sentenced an accused person to death after reversing an acquittal or withdrawing a case for trial and convicting the accused.
- The High Court can also certify cases as fit for appeal to the Supreme Court.
- High Court Certification:
- For a case to be appealed to the Supreme Court, the High Court must certify that it is fit for appeal under Article 134A, ensuring that only significant cases reach the Supreme Court.
- Parliamentary Powers:
- Parliament has the authority to confer additional appellate powers on the Supreme Court concerning criminal proceedings, subject to specified conditions and limitations.
- Special Leave to Appeal:
- The Supreme Court retains its power to grant special leave to appeal under Article 136, allowing it to hear appeals in cases where it deems necessary, even if the conditions of Article 134 are not met.
Key Points:
- Focused Jurisdiction: Ensures the Supreme Court deals with significant criminal cases, particularly those involving death sentences and substantial legal questions.
- High Court Gatekeeping: The certification process by High Courts acts as a filter, allowing only important criminal cases to be appealed to the Supreme Court.
- Judicial Flexibility: The Supreme Court’s power to grant special leave to appeal ensures that justice can be served in exceptional cases, regardless of procedural constraints.
Important Cases and Commissions Related to Article 134
Cases:
- Bachan Singh vs. State of Punjab (1980): A landmark case in which the Supreme Court addressed the constitutionality of the death penalty and outlined guidelines for its application, emphasizing its appellate jurisdiction in capital punishment cases.
- K.M. Nanavati vs. State of Maharashtra (1961): A notable case where the Supreme Court exercised its appellate jurisdiction to review a conviction in a criminal proceeding involving significant public and legal interest.
Commissions:
- Law Commission of India: Various reports have emphasized the need for effective appellate mechanisms in criminal justice to ensure fair trials and just outcomes.
- National Commission to Review the Working of the Constitution (NCRWC) (2002): Recommended measures to streamline the appellate process and enhance the efficiency of the Supreme Court in handling criminal cases.
Previous Year Prelims Questions Related to Article 134
- (UPSC Prelims 2017) Under Article 134, an appeal to the Supreme Court in a criminal matter involves:
- A. Any judgment of a High Court
- B. Any sentence by a lower court
- C. Cases where the High Court has sentenced an accused to death
- D. Any order by the High Court Correct Answer: C. Cases where the High Court has sentenced an accused to death
- (UPSC Prelims 2019) Which Article of the Indian Constitution provides the Supreme Court with appellate jurisdiction in criminal matters involving death sentences?
- A. Article 132
- B. Article 133
- C. Article 134
- D. Article 136 Correct Answer: C. Article 134
Previous Year Mains Questions Related to Article 134
- Mains 2016: “Discuss the significance of Article 134 in the context of the Supreme Court’s appellate jurisdiction in criminal matters. How does this article ensure that significant criminal cases are addressed by the highest judicial authority?”
- Mains 2019: “Analyze the role of High Court certification under Article 134A in appeals to the Supreme Court under Article 134. How does this certification process impact the administration of criminal justice in India?”
Additional Insights:
- Ensuring Fairness in Capital Cases: Article 134 plays a crucial role in ensuring that cases involving the death penalty are reviewed by the Supreme Court, promoting fairness and thorough scrutiny.
- Collaborative Judicial Process: The certification process ensures collaboration between High Courts and the Supreme Court, promoting the efficient handling of significant criminal cases.
- Balancing Judicial Workload: By limiting the Supreme Court’s appellate jurisdiction to substantial cases, Article 134 helps manage the Court’s workload, ensuring it can focus on the most critical legal issues.
Understanding Article 134 is crucial for UPSC aspirants as it outlines the Supreme Court’s appellate jurisdiction in criminal matters, ensuring that significant cases involving substantial legal questions and severe penalties, like death sentences, are reviewed by the highest judicial authority. This knowledge is essential for both preliminary and main examinations, offering a comprehensive understanding of the constitutional provisions that govern the appellate process and the role of the judiciary in upholding criminal justice in India.