Saturday, 16 December 2023

 

 

Cross-examination. (This topic is useful for both bench and bar).

Written by,

Malik Munir Ahmed Joyia.

District & Session Judge.

Judge Banking Court-V

Lahore.

Phone #                 0303-9466323

                              0346-6249001

Gmail Address:      malikmunir9014@gmail.com

Purpose of cross-examination.

                                                        i.                    To check the credibility of the witness.

                                                      ii.                    To impeach the accuracy of the evidence.

                                                    iii.                    To expose and bring on record the facts which the witness has not deposed and these facts are useful for the cross examiner.

                                                    iv.                    To confront the facts which the witness has improved to fulfill the lacunas of his case.

 Legal terms used in cross-examination.

                                                        i.                    Statement.

                                                      ii.                    Facts.

                                                    iii.                    Facts and opinion.

                                                    iv.                    Evidence.

                                                      v.                    Testimony.

                                                    vi.                    Voluntary statement.

                                                  vii.                    Obliging concession.

                                                viii.                    Previous statement.

                                                    ix.                    Narration.

                                                      x.                    Leading questions.

                                                    xi.                    Suggestion.

                                                  xii.                    Discrepancies

                                                xiii.                    Confrontation.

                                                xiv.                    Procedure of Confrontation.

                                                  xv.                    Contradiction.

                                                xvi.                    Dishonest improvement / embellishment.

                                              xvii.                    First version,confession & defense version.

                                            xviii.                    Un-rebutted evidence.

                                                xix.                    Probability and benefit of doubt.

                                                  xx.                    Blood Stained earth.

                                                xxi.                    Scale site-plan.

                                              xxii.                    Inquest reportInquest-report/Naqsha Sorat-e-Hal/Report Marg.

                                            xxiii.                    Police File / Zimni /case diary and its use.

                                              xxiv.             Use of modern evidence like  audio or video  and its legal value.

 

Cross-examination by defense.

Sequence of cross-examination.

Settled principles of cross-examination.

Cross-examination by trial judge.

Cross-examination by prosecutor on hostile witness.

Re-examination.

Cross-examination on civil side.

 

What is cross-examination; It comes under chapter 10 in articles 133, 134, 135,136,137,138,140,141,150, 161 of the Qanun-e-Shahadat Order, 1984 and 162 Criminal procedure code (Cr.P.C). A statement on oath of a witness before the court is known as the examination-in-chief. When the adverse party tries to falsify/ controvert the said examination- in-chief, said process is amount to cross-examination. After cross-examination, if any ambiguity come into picture, the party who produce the witness, can get re-examine said witness after seeking permission from the court. After that the other party can be given opportunity with the permission of the court to conduct the cross-examination, if so required.

The cross-examination is an art through which the advocates know the modes  to cross-examine the witness. The cross-examination requires hard work and talent of the advocates. It can also be defined as the interrogation of a witness called by one's opponent. The cross-examination is used either to abolish or weaken the power of evidence, which is already anticipated by a witness. It plays an important role to provide justice to the clients during the trial of each case. It is the professional duty of the advocates towards their client, to conduct better cross-examination, because it is not a matter of mere glory and fame. An advocate can learn the art of cross-examination not only by observing trial, but by conducting the cross-examination personally on the witness. The main aim of the cross-examination is to elicit favorable facts from the witness or to shake the credibility of the witness.

The cross-examination is also done to find out the truth and  detection of the lie in the testimony of the witness. It is important to remember that the justice should not be denied by the improper cross-examination. The advocates should clearly go through those points which they wish to ask before initiating cross-examination on the witness. Generally, cross-examination means to test the credibility of a witness and to bring true facts on the record, which the witness has either not brought on record or has deliberately concealed. The cross-examination is the most powerful engine as invented by the human civilization during the experience of centuries. The cross-examination may differ from case to case and person to person. The age, position, status, expression, qualification and expertise etc of the witness can be the useful topics for the cross-examiners. Right to cross-examine flows from the principle of natural justice that evidence may not be read against a party, until the same has been subjected to cross-examination or at least an opportunity is given for the cross-examination.

 Right of cross-examination is not mere formality, but is the only way conferred by law to check the truthfulness of case of opponent party. The worth of an advocate is based on the practice and procedure through which he conducts cross-examination. The cross-examination cannot be confined to the facts to which the witness testifies in his examination-in-chief. He can be cross-examined as to the whole of the case, but it confines to the matter which are relevant to the main case.  A witness can be questioned about his conduct, integrity, his enmity with the other party and his interest in giving evidence. To shake the creditability of a witness, the questions can be asked about his previous inconsistent statements about any relevant fact. Indecent and scandalous questions can also be asked by the advocate at the time of cross-examination, if they relate to the fact in issue. The questions intended to insult or annoy the witness should be forbidden by the court, even though the question may seem to be proper. Evidentiary value of any such statement of witness is to be determined by the court at the time of final judgment. Further in section 363 Cr.P.C a judge can pass remarks about the demeanor of the witness, which is also amount to some sort of cross-examination. The main purpose of the cross- examination is as under;

                                                           i.        To check the credibility of the witness.

                                                         ii.        To impeach the accuracy of the evidence.

                                                       iii.        To expose and bring on record the facts which the witness has not deposed and said facts are useful for   the cross-examiner.

                                                       iv.        To confront the facts which the witness has improved to fulfill the lacunas of his case.

There is no hard and fast rule for the cross-examination. Different kinds of witnesses require different treatment. Some witnesses are formal in nature and normally, no cross-examination is required on such witnesses. To conduct proper cross-examination, the concerned  advocate  must know what onus he has  to discharge, what issues   is to be proved  and what defense he has  to take. He can cement the   base of his defense, while making questions in the cross-examination and then prove the same after the case of his opponent is over. The witness may be questioned to establish his bias, interest, corruption or perjury. He may be questioned to discover his position with reference to the controversy or to shake his credit by drawing his attention to any of his previous inconsistent statement as to relevant fact or to his previous statement containing admission. It is well said that best facts of a criminal case are known to the police and lawyers and the cases are either win or lose in the chamber of the advocates before the trial commence.

Actually, the cross-examination is an art and during my career as judge, I observed that most of the lawyers were struggling in this field and even they are not aware about the basic legal terms like, facts, statements, evidence, testimony, narration, suggestion, improvements dishonest improvement and confrontation etc. They do not know the basic principle of cross-examination that what question is to be asked and what not. Some time they conduct cross-examination without preparation.

Legal terms used in cross-examination:

Statement: A statement means the formal presentation of facts or the act of stating and reciting of facts. In criminal side its kinds are as under:-

        Statement of the witnesses before the court with or without oath.

         Statement of witnesses before police officers u/s 161 Cr.P.C.

         Statement of the witnesses before magistrate u/s 164 Cr.P.C.

        Statement of accused before the trial court u/s 342 and 340(2) Cr.P.C.

        Voluntary statement.

        Previous statement.

Fact: Fact means a circumstance, event or occurrence as actually, takes or took place or a physical object or appearance. It also means thing, state of things, or relation of things which can be perceived through senses.  There are various kinds of fact like, fact in issue, relevant fact and fact which are not relevant and otherwise become relevant.

        Evidence can be given qua fact in issue or relevant fact under article 18 of Qanun-e-Shahdat Order 1984.

        Evidence can be given about existence or non-existence of every fact in issue or of such other fact like the fact which are the occasion, cause or effect of fact in issue.

        Motive, preparation, previous or subsequent conduct of the accused can be relevant fact under article 21 of Qanun-e-Shahdat Order 1984, while it got no concern with the fact in issue.

        Some fact necessary to explain or introduce the relevant facts also can be relevant to fact in issue. Please see article 22 of Qanun-e-Shahdat Order 1984. Identification parade is one of the examples of said situation.

        Probability is a piece of evidence and can be relied upon as an item to prove a fact. Please see 2006 YLR 251

 

Fact and opinion; As per article 2(d), Qanun-e- Shahadat order, 1984,  fact and an opinion  are two different terms of law, having different consequences. For example a doctor who used to conduct the post -mortem examination of a dead body, he describes the nature, seat and number of injuries, which he observes during post mortem report, At the same moment, he can also make his opinion as to the manner through which these injuries might have been caused and as to cause of the death. As an expert,  he  describes  the number, position and nature of injuries, as he has actually observed, perceived and noticed, but to depose about the manner and weapon of offence  with  which these injuries were caused and  the cause of the death,  is the simple  opinion of the doctor drawn from the facts  as he  observed  during examination of the dead body. Please see PLD 1992 Lah. 314.

Evidence; Evidence means to confirm, attest, explain corroborate and demonstrate the disputed facts on oath before the court, so that the    court can make the conclusion of the matter in issue between the parties. The word evidence is an exhaustive term and includes all statements which the court permits or requires to be made before it, by the witnesses, in relation to matters of fact under inquiry or trial. Such statements are called oral evidence, and all documents produced for the perusal of the court are called documentary evidence.

Testimony; Evidence and testimony are interchangeable words, but in article 3 and 17 of Qanun-e-Shahdat order1984, word testimony has been used to that of evidence.  Testimony means the statements of the parties, witnesses and documents which are allowed under Qanun-e-Shahdat Order 1984, to be produced before the court to prove fact in issue or relevant fact. In testimony, competency of the witness, court, oath of the witness and cross-examination would be the basic factors. Without cross-examination the evidence cannot get the status of testimony. So to make the evidence testimony cross-examination is obligatory. But normally, we use the word evidence to that testimony which is wrong practice.

Voluntary statement; In cross-examination, we face the issue of voluntary statement on the part of witness, when he tries to further explain his answer. There is no provision of voluntary statement in Qanun-e-Shahdat order 1984, and it also got no value in the eye of law and judges normally allow such type explanation /answer to continue the process of evidence. It has been explained in case title Mushtaq Ahmed V Mohammed Sarwer and another that voluntary statement by a witness in cross-examination has no evidentiary value. Such voluntary evidence is against the rule of re-examination as contemplated under Art.133 of Qanun-e-Shahadat order 1984.

Obliging concession; It means to give undue favor to defense. Sometime formal witnesses, doctors and IOs give favorable answer in cross-examination to favor the defense and said answers are always against the record and are normally made in league with the defense side to weaken the case of the prosecution. If the court come to the conclusion that answers of said pw is given to weak the prosecution case and to support the defense version, then court can ignore it. Said situation as per law is known as obliging concession and the court of law discourage said steps of the witnesses and no benefit is advanced to the defense. Please see  landmark judgments Habib-Ullah case reported in PLD 69 Supreme Court, page 127, Muhammad Shareef case reported in 1976 Supreme Court, 452 and 2005 SCMR, 1431,2009 SCMR 407 and 2009 Pcrlj 894 FSC.

Previous statement; Said statement is very material in criminal trial. It has been explained in article 140 of Qanun-e-Shahadat order 1984, and section 162 crpc. If a statement recorded in discharge of official duty in the same case or in some different case, having relevancy with the fact in issue, can be brought on record to confront its deponent, when he comes to court to make evidence. Article 46 and 47 of The Qanun-e-shahadat Order, 1984 are also relevant in this respect.

Narration; Narration is the act of telling a story, usually in some kinds of chronological orders. Narration generally, means any kind of explaining or telling of something. As per legal practice narration means the examination-in-chief of the witness and answer of the witness as given against a general question, put in the cross-examination. All the examination-in-chief and most of the cross- examination are normally done in the form of narration, but there is no restriction to do the same in the question and answer shape.

Leading questions; it means a question which promotes or encourages the answer wanted to the maker of the question. It is further explained by the superior courts that the real meaning of this question is that a question which suggests the answer (yes) is a leading question. A question which suggests only the answer (no) also is leading question, but a question which may be answered either in yes or no, and suggests neither answer as the correct one, is not leading.

Suggestion; it means an idea or plan put forward for the consideration to other person. In our judicial system, it is normally used by defense counsel to put their stance/version to the pw, during cross-examination to rebut him and advance/introduce the case of defense and if the same is wrongly put, it can promote the case of the prosecution. As per law, settled in PLJ 1991 criminal case Lahore 249, 2010 P Cr. L J, 1726 and Muhammad Shah case, reported in 2010 SCMR page 1009, said suggestions never got the status of corroboration or direct evidence. It is the prosecution which has to prove its case independently. On the basis of one favorable answer by the pw to the defense or any suggestion in favor of the prosecution, would not matter, rather whole evidence is to be looked into, while making any conclusion of the case. In 2006 SCMR, 577, otherwise view is taken and it was held that said situation will be addressed in favor of prosecution, but it is a minority view.

Discrepancies; It means when there is a difference between two things that should be alike. In ocular account normally minor discrepancies crop up due to time factor, but if they do not touch the intrinsic value of evidence, then same will not matter. Please see 2003 SCMR 884 Mandoos Khan case, 2013 P.Cr.R 1028, 2013 P.Cr.L.J 688 and PLD 2013 586.It is added that to address said discrepancies, time  factor will be kept in mind, because it plays vital role in memory of the witness.

Confrontation; It is a basic right of an accused in a criminal trial to confront the testimony of opponent witness in his trial, while using the opportunity of cross-examination. In our judicial system confrontation means right of the accused through which he can confront the witness with his previous statement recorded under section 161 Cr.PC or a      ny statement made by him before any even administrative forum which is related to the matter in issue in 162 crpc and in article 141 of Qanun-e-Shahdat etc, when the witness avoids to accept/disclose his actual statement recorded before the police u/s 161 Cr.P.C, or any other forum of law. Normally, this practice is done when the witness try to improve his case to fulfill the lacunas or to disown anything goes against him. Actually, witness makes an effort to deprive the accused qua said valuable right, so that the accused could not confront said situation. Said act of the witness shakes his credibility. It is added that confrontation is allowed with previous statement of the witness and nothing else. Please see relevant case law PLD 1965 Supreme Court 188 and 1995 MLD 1635 Federal Shariat Court and PLD 2013 SC 386.

Note: Prosecution could not be permitted to confront a witness with his previous statement recorded u/s 161 crpc for the purpose of contradicting him even after being declared hostile.

 Procedure of confrontation; To confront a witness with his previous statement is somehow complicated process. I just try to simplify it in the light of my experience.  The proper way is to ask the witness, whether he has made such and such statement before police or before any other quasi-judicial or administrative forum. We are normally confused, if the witness replies in yes, the previous statements in writing need not to be proved, because he himself admitted the said statement before the court and court will see the fate of said statement. If the witness denies his previous statement or states that he does not remember any such statement, then confrontation is needed and said statement be placed on record as ex; DA, B etc, so the court could see the authenticity of statement.

The defense counsel will read out to the witness the relevant portion of his previous statement and give him a chance to explain or reconcile the same. For example, if pw stated in his previous statement that he reached at the place of occurrence on hearing the hue and cry, when the victim was assaulted, but in his examination-in-chief before the court, he states that he reached at the place of occurrence, while passing through near the same. There is a contradiction in his two statements and this can be confronted, if so needed by the defense and defense can put his previous statement as DA etc on the record, so that the court can observe the actual position. If said practice is not done, then the statement given before the court on oath would be believed as it is, and no benefit of previous statement can be taken by the defense.

 

During the dictation of cross-examination, when the defense side tries to bring on record anything left by the witness, which is in favor of the defense or anything added by the pw, which is amount to fulfill the lacuna, then after  seeing statement of the pw u/s 161 crpc and the examination-in-chief of the pw  and if any addition is made then the said situation can be confronted with the previous statement under section 162 crpc and article 140 of the Qanun-e-Shahdat Order, 1984 as the case may be, otherwise the same would be used against the defense.In the same way, when anything is omitted which was mentioned in the previous statement and the same is useful for the defense, then the defense can bring the same on record.

FIR is mere first information having no evidentiary value, until its scribe (we normally use the word scriber to that of scribe which wrong practice) proves its contents before the court. Its maker can be confronted with it, in 140 Qanun-e-Shahadat Order 1984. Its maker can be corroborated in 153 Qanun-e-Shahadat Order 1984. It can be proved against its maker in 34 Qanun-e-Shahadat Order 1984. Except this it got no role in criminal trial. Mere improvements are not fatal until these become dishonest. To declare them dishonest, the criterion is confrontation, by defense and court itself can't adopt said role. So, we ourselves can't compare the contents of the FIR, with its maker evidence, we being procedural court has to follow the settle rules of evidence. As far as 161 crpc statements are concerned, its use is to confront the   witnesses in 162 crpc and nothing else, we ourselves can't compare its contents with testimony of the witness.

Contradiction; It means the opposition of two ideas which are the subject of one and the same proposition. When two witnesses or other persons, state things directly opposed to each other, it amount to contradiction in their evidence. In our judicial system contradiction and confrontation are two different things. Contradiction means a conflict in the evidence of pws, if said contradictions are minor in nature and are not touching and disturbing the roots of the charge, then same are normally ignored, otherwise said situation is   addressed in favor of defense. Confrontation is the move of the defense through which the testimony of the witness is checked qua his previous statement. For further clarification please see PLJ 2013 Cr.P.C 319 and 2014 Pcrlj 885. Discrepancies in the detail of the facts do not amount to contradiction. Please see PLD 2005 Peshawar 166. If discrepancies are minor in nature, then carry no weight. Please see 1995 SCMR 1793. It is added that minor contradiction are quite natural, because with the passage of time the witness cannot recollect the actual/minute detail of the occurrence and due to this minor contradiction are normally ignored.

Dishonest improvement/embellishment; Dishonest improvement means to add something in the previous statement recorded u/s 161 Cr.P.C, to strengthen the case after seeking some legal assistance, but when the same are duly confronted and once the same found to be deliberate and dishonest, it costs serious doubts on the veracity of such witness. Please see 1993 SCMR 550. When a witness makes improvements or omissions in his deposition, he agrees to own dishonesty, which alone is sufficient to discard evidence of such dishonest witness. Please see 2019 MLD 1821. If these improvements are minor in nature. it was held in  2008 SCMR, 8, 2010 SCMR, 385, 2003 SCMR, 884, 2013 SCMR 480, and 2012 SCMR, 1869 that same would not matter.

First version, confession & defense version; These are two different terms having different consequences. First version means the statement/ version   of the accused recorded by the I.O, when first time the accused appears before the I.O and the I.O records it under the head of “berderiaft”. Normally, it is based on reality. As per article 27 of the Qanun-e-Shahadat Order, 1984 the same is admissible in evidence. As a general rule evidence not forming part of the transaction is not admissible, whereas articles 27&28 of the Qanun-e-Shahadat Order, 1984 are  exceptions to the said general principle and the facts which are relevant facts to prove the status/mind of the accused are admissible in evidence like the guilt, intent, knowledge, negligence, malice etc of the accused. Law is settled that the accused can take the copy of his first version and during cross-examination, he can bring the same on record under Article 27 of the Qanun-e-Shahdat Order 1984, by putting question to the I.O. In the same way, any confession made by the accused before the police can also be brought on record under the said article,but this facility is no more available to the prosecution side and whatever the first version or confession of the accused recorded by the I.O, the prosecution cannot bring the same on record while putting the same to the I.O. Further see Section 162 and 172 Cr.P.C under which the accused cannot be restricted to cross-examine the I.O, or the Magistrate who recorded his confession and he place it on record and can use the same in his favour. Please see Liaqat Ali case reported in 1998 P.Cr.L.J 216, PLD 1974 Karachi 91 and Aslam case reported in PLD 1995 Lahore 632 and PLD 1971  SC, 751. 

The statement recorded u/s 161 Cr.PC or in the body of the police file is a relevant fact under Article 49 of the Qanun-e-Shahdat Order 1984. Qanun-e-Shahdat Order 1984 is an independent law to other procedural laws i.e. Cr.P.C and under Article 15 of the Qanun-e-Shahdat Order 1984 court can compel the I.O, to see the police file and give correct answer and the privilege of the I.O, u/s 172 Cr.P.C is of no avail to him due to article 15 of the Qanun-e-Shahdat Order 1984.

As per settled view of the superior courts, accused is the favorite child of law and he can take a number of pleas in his defense and is not bound to prove the same. This situation has been explained in Azhar Iqbal case, reported in 2013 SCMR 383, whereby it has been clearly opined that in case the accused admits the murder due to Ghayret or due to other general or special exceptions, then too, he cannot be convicted until, unless the prosecution proves its case independently.

Accused is so favorite child of the law that if he has not taken the plea of self-defense and the court comes to the conclusion that the accused committed the occurrence due to self-defense, then while believing the same, benefit can be given to the accused about the said plea. Please see, 2008 YLR 1315 Umer Draz case, 2005 PCr.LJ 1689, PLD 2004 SC 244 and 2011 SCMR 45.After 18th Amendment under Article 10 (A) privilege in the shape of due process and fair trial is also given to the accused. So, in said situation courts are bound to give full-fledged opportunity of hearing and defense to the accused except scandalous questions. If the accused put scandalous questions then he loses his status as favourite child of the court and benefit of 382 B Cr.P.C  can also be withheld.

Sometime we face the issue when any accused come under section 340 (2) Cr.P.C as his own witness and deposes on oath before the court, then all the procedure for confrontation of previous statement provided for the prosecution /defense witnesses would be the same. Here if the prosecution side wants to confront the first version of the accused as got recorded by him before the I.O, then the court will allow the same.

Defense version means the version taken by the defense counsel during the cross-examination at the eye-witnesses, and at the I.Os. Further the defense version is also taken in the statement of the accused under section 342 crpc and if the accused himself appeares as his own witness u/s 340 crpc  then, he also takes his defence version on oath. It may be in the light of the first version as discussed above and it may be independent to that of said first  version of the accused. The consequences of both the same are  different to each other as discussed above.

Un-rebutted evidence; Please see the Article 113,133 and 134 of the Qanun-e-Shahdat Order 1984, whereby it was explained that if the evidence is un-rebutted, then it would be admissible in evidence. Please see 2007 SCMR 1700, whereby it was held that facts asserted by one party remain un-challenged would amount to admission, so to confront and controvert the incriminating evidence is obligatory, otherwise it would be used against the opponent. Evidence of the eye-witness in the shape of examination-in-chief without cross-examination is admissible in evidence, but it remains only evidence and after cross-examination said evidence got the status of testimony which is more authentic and reliable. So un-challenged evidence  can  be legally taken into consideration, if it is fully corroborated/ supported by other pieces of evidence like medical evidence and recoveries etc, To believe it against the defense  extra care and caution is required, because without cross-examination, it remain evidence and cannot get the status of testimony, because for that purpose cross-examination is necessary.

Evidence of an eye-witness in the form of his examination-in-chief could not be rejected on the simple proposition that he was not subjected to cross-examination, if the accused had himself avoided in a deliberate and calculated manner to avail such an opportunity. Distinction had to be drawn between these two situations, one where opportunity to cross-examination was not given or denied to a party, and second, where it was given, but deliberately not availed of by the accused. In the latter position the accused can badly suffer. If the right to cross, was reserved as per request of defense and the witness is died or not available for cross-examination, then the defense will suffer. Please see PLD 2010 SC 642 Arbab Tsleem case, PLJ 2011 SC 117 and PLJ 2018 SC453 Sadiq case.

In PLD 2001 Lahore 463 otherwise view is taken but after the views of apex court said view will not matter.

In civil case, said situation effect otherwise. The principle that a statement or any part of statement, which remain un-rebutted amount to admission does not attract in criminal cases, because in criminal side prosecution has to prove its case on its own, beyond any shadow of doubt, but in civil cases preponderance of probabilities of the evidence of the parties matter. So question of un-rebuttal in civil matter is important, but this is not so material in criminal trial. Please see 2018 SCMR 149.

During cross-examination defense must controvert the evidence of witnesses and put his defense in the shape of suggestions to all type of witnesses like eye/recovery witness etc that you are inimical towards the accused etc and due to this you made false evidence. Only plea taken by the accused in his examination recorded under Section 342, Cr.P.C, that the case is false and has been registered under the political influence etc, is not sufficient to create doubt in the prosecution case. Please see 2008 SCMR 387.Defence counsel has to build its defense during cross-examination, because as per section 342 crpc, there is no room for the defense lawyer to make answers on behalf of the accused, if so asked by the court under said section.

 

Probability and benefit of doubt; These are two different terms of law and both said terms have not been explained in any code, however these have been taken up in various judgment of superior court. A probability is a state of things that reflects the chance or likelihood that a particular event can occur. Probabilities can be expressed in proportion like its range from 0 to 1, and these can also be expressed in percentages ranging from 0% to 100 %. While word benefit means advantage, gain or interest and doubt mean misgiving, suspicion and uncertainty etc. The accused is entitled to have, the benefit of doubt as a matter of right. Accused being a favorite child of law is to be treated as innocent unless he is proved on the basis of best possible evidence that he was connected with the commission of crime.

Blood Stained earth;It got importance in murder trial when the place of occurrence is disputed or the dead body is not verifiable due to certain reason. Police normally collect report without comparison report whether said blood was of the deceased or not. Simple report that it is human blood is not sufficient. To make sure that the deceased was murdered at the place of occurrence, the collection of comparison report  of the deceased blood is  necessary.  In the said situation no need to cross-examine the said aspect of the case.

Scale site plan ;Scale-site plan is not necessary in all  the cases, it is the discretion of the IO, to get prepare  it if needed. It is not substantive piece of residence. It can be helpful to cross-examine the eye witnesses qua their location and other evidence about mode of occurance.Now in the present era when everybody has video cameras in his mobile, the I.O should prepare the video of the crime scene, but police avoid to do so and take the control of everything to prepare the police report as per their need. It is a basic evidence and if court see, the said video, then most of the things become clear about the occurrence.

 

 

Inquest reportInquest-report/Naqsha Sorat-e-Hal/Report Marg; These three terms are one and the same and  come under section 174 Cr.P.C and police rules 25, 31-35.Inquest report means to observe the cause of death of a person and not the person who had caused the death. It is the duty of police to observe whether it was natural death or by violence or by poisoning, when police visits the place of occurrence and dead body is lying there. Police is bound to mention the cause of death. If said report does not disclose the name of the accused, then it will not matter because its basic requirement is to disclose the cause of death and not the killer.Please see PLD 2006 Peshawer 5 and NLR 1982, Cr.L.J, 452.Said report states the apparent cause of death,   provide description of any mark or marks of violence which may be found on the body and describe the manner in which and the weapon or instrument with which such marks appear to have been inflicted.

Said report is signed by the police officer conducting the investigation.The plan of the scene of death and the detail of clothing, etc and a list of the articles lying with the body are mentioned in said report. In cases of death by hanging, the report shall give particulars as to the height and sufficiency of the support and the nature of the thing used to bear the weight of the body. In drowning cases the depth of the water shall be stated



Police   file / Zimni /case diary and its use.Case dairy/ zimni is different to the station / general diary(roznamch). Case diaries are recorded by the I.O during the investigation of the case,on the printed pages as provided to the I.O by his department. Every page on which police diary is  written got its number, so that the check on the police investigation be maintained, but police badly violates it and almost in the criminal case, the sequence of the page number is disturbed. I.O is bound to send the one carbon copy of his case diary to the DPO office,but this rules is also badly violated by the police. These are some reasons due to which the opinion of the police is always doubted.

Defence cannot claim the copies of the case diaries under Section 265 C /241 cprc. In the same way, during investigation   processs the  accused cannot claim  access to said diaries. The reason behind it is that the plan of investigation of the I.O, should not be in the knowledge of the accused.If the accused will be aware about the line of action of the I.O, then the accused can manage to disappear the incriminating evidence as the I.O wants to procure against the accused. However the statement recorded in boiled from of PWs can be given to the accused.

When police report under Section 173 Cr.P.C is placed before trial court and trial court take the cognizance of the case, then the concerned I.O, hand over the police file to the Naib court of the trial court. When 173 Cr.P.C,  report submitted before trial court and trial court take the cognizance , then said report  got the status of judicial file and it is the record of trial court and trial judge can issue the attested copies of said report as per law.

But as far as police file is concerned, the same is not judicial or court record. We cannot issue the copies of the same to the accused. It can only be used by the I.Os to refresh their memories and defence counsel can get use it to confront the I.O and to put the  first version  of the accused on court record. Defence also can get bring on record the material which is favourable to the accused, as collected by the I.O during  investigation process, but so such facility is available to the prosecution. Actually police file is the record of the public prosecutor attached with the court.

Some time we face the issue of using the case diary in the criminal trial on the part of the defense side and if the court deem it proper to reach at the just conclusion of the case then the court can direct the investigation officer to look into the case diary and make the answer and the investigation officer would be bound to do so because it is the right of the defense. As per wisdom laid in  section 265, Cr.P.C and  further explained in 1976 SCMR 506 it is held that police diary cannot be corelated with the statements of all the witnesses recorded by the police.   Further case  relevant law on this point has been explained in PLD 1992 Lahore 336.It is added that the procecution side cannot use the case diries in thieir favour  against  the defence.

                                   Roznamcha / Station Diary genral  Dairy;

A diary maintained by the police to enter any significant event, incident, offence or crime etc, on day to day basis is known as police diary and It  can be  produced  in the evidence. Reports about non-cognizable offence  are also entered in said register. In addition to that all the proceedings of the I.O are given in that register. Accused cannot claim the copy of said register under Section 265-C /241 Cr.P.C. However, to confront the I.O, the said register can be summoned by the court at short notice to the concerned police station. In criminal trial normally, we use it to check the investigation process of the I.O, because every I.O is bound to enter his departure and arrival with detail of constables accompanying him. If any thing collected  by the I.O, he will enter it in the said register. I.O will also mention the arrest of the every accused in the said register. If the investigation proceeding of the I.O got no support in the said register about his departure / arrival etc with reference to the case, then prosecution will suffer. To reach at just conclusion of the case the court  under Article 140 of Qanun-e-Shahadat Order, 1984  can bring the entry in said register on record and it would amount to statement.

Use of modern evidence like  audio or video  and its legal value;

 

The House of Lords in case titled, Regina (Quintavalle) v. Secretary of State for Health  held that the laws have to be made  in the light of  development  in scientific knowledge and  utilize it in judicial  system. Our  courts of law  in criminal and  civil side can take judicial notice of the credible scientific development under Article 112, Qanun-e-Shahadat, 1984. In the present era, we  cannot  ignore  the  relevant  scientific research and development, which has already been recognized and acknowledged by the courts in various other judicial systems.Scientific research can help and assist the court in understanding and appreciating evidence  properly and  the  object of natural and substantial justice can be ensuerd while using latest technology to collect/ appreciate the evidence.In this regard article 164 of  the Qanun-e-shahadat Order, 1984  is there, but to utilize modern devices properly  further legislation is required  because our scheme of law  consider it just as expert opinion and we still prefer the direct or circumstantial evidence etc. It is held in PLD 2019 SC 196 that I.O can get record the statement of  the complainant and the pw under Section 161 Cr.P.C through audio or video or any other mode of electronic media.

 

No audio or video tape straightaway  can be relied upon by a court until the same is proved to be genuine and not tampered with.A forensic report  of audio or video tape  prepared Punjab Forensic Science Agency  is per se admissible in evidence  under section 9(3) of  said agency.Under Article 164 of the Qanun-e-Shahadat Order, 1984  a court can  allow  such type evidence  to be produced  in evidence  in accordance with the law of evidence.Accuracy of the recording must be proved.An audio or video tape  sought to be produced in evidence must be the actual record of the conversation as and when it was made or of the event as and when it took place.The person recorded the conversation or event is to be produced as witness.The audio  or video tape must be played in the court and it must  be clearly audible or viewable.

The person recording the conversation or event must identify the voice of the person speaking or the person seen or the voice or person seen may be identified by any other person who recognizes such voice or person.Any other person present at the time of making of the conversation or taking place of the event may also testify in support of the conversation heard in the audio tape or the event shown in the video.Such type evidence must  be relevant to the controversy and otherwise admissible. Safe custody of the audio tape or video after its preparation till production before the court must be proved.The transcript of the audio tape or video must have been prepared under independent supervision and control.  An audio tape or video produced at a late stage of a judicial proceeding may be looked at with suspicion. A formal application has to be filed before the court by the person desiring an audio tape or video to be brought on the record of the case as evidence.Please  see PLD 2019 SC 675.In PLD 2019 Supreme Court of Pakistan page 196, it is held  that in the present era keeping in view the need of latest technology, the audio and vedio are accepted as solid evidence. 

 

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Note: When an advocate will clear qua above said terms of law, he would be in better position to cross-examine the witnesses.

Cross-examination by defense: It is added that normal concept is that the cross-examination is done only by the defense counsel, but reality is otherwise, even prosecution counsel and even trial judge can also do said job, if so required. Concept of joint cross-examination is not recognized by the law. In case where there are more than one accused, the judge while recording the cross-examination of a witness should mention the name of the accused and/or his lawyer who is cross-examining the witness. Sometime the accused engaged more than one counsel, only one lawyer is allowed to cross the witness on behalf of the accused. Cross-examination by accused himself is no substitute for cross-examination by the counsel. Please see 1993 SCMR 550.Further to conduct relevant and legal cross-examination, one should be clear about the legal terms like, facts, statements, evidence, narration, suggestion, improvements dishonest improvement, and confrontation etc. Even some lawyers are not aware about the difference amongst said terms which are quite necessary for proper cross-examination. The defense counsel normally can ask only three types of questions in cross-examination, in the form of narration, suggestions, and leading questions.

Normally, the defense counsel ask question in the form of narration and the witnesses also answers it, in the form of narration. Most of the cross-examination is in the form of narration, But some time, when the witness is telling lie, or he wants to conceal or confuse the real facts, then the defense lawyer can suggest the witnesses the actual situation. Actually, narration is the stance of the witnesses, while suggestion is the stance of the opponent party, who conduct cross-examination and during this through suggestion said party put its defense to the witnesses. So, any question which was asked in the form of narration is not so dangerous, but any suggestion made by the counsel which either answered in positive or negative can be used against the party making it to the witnesses.

Further after  going through the  report u/s 173 Cr.P.C, police file, visiting of the place of occurrence, discussion of the case with the party , proper knowledge of medical jurisprudence and forensic science are also helpful in cross-examination. In murder, injury and rape cases, the knowledge of the doctors is normally very poor and during cross-examination, they can easily be knocked out by the competent defense counsel. In our  judicial system normally defense lawyers conduct a lengthy cross-examination, not to assist the court to arrive at just conclusion, but they do so  for  the manipulation of  mistakes and sometime said practice is done just to pay the gallery.

No proper formula or procedure can be prescribed to conduct proper cross-examination, but after going through the cross-examination as conducted by some competent defense lawyers, some hints can be taken and said right is to be exercised within framework provided under articles 141 and 151 of Qanun-e-Shahadat Order, 1984. It is not necessary that witness should only reply the question as per wishes of the defense side, he can explain his answer as he wishes. No restriction can be imposed upon said explanation. It is the basic duty of the trial judge to ensure the prestige and dignity of the witnesses during the cross-examination and witness should not be harassed by the defense counsel. Actually, a witness   comes forward in aid of justice before the court of law. Even a man with most brilliant qualities would collapse, if he will be subjected to filthy, lengthy and irrelevant cross-examination, so court should check such type practice.

  I just refer my own judgment dated 20.09.2017 passed in case titled the state v Mohammed Arshed, sessions case No.67/S.C. of 2017 and sessions trial No.12/S.C of 2017, FIR No. 448/2017 dated 12.08.2017 u/s 302 PPC police station Sadar Lodhran, wherein following factors were explained and these factors can be material in cros-examining  to observe the availability of the eyewitnesses at the time/scene of occurrence:-

(I)             Residence, age and profession of the witness.

(II)           Routine of daily life of the witness.

(III)        Relationship of the witness with the deceased.

(IV)        Distance between the places of residence of the pws.

(V)          Distance of the place of occurrence from the residednce of the  pws.

(VI)       The location of place of occurrence.

(VII)     Approaches/passages towards place of occurrence.

 

(i)             The distance amongst the pws, the deceased and the accused at the time of occurrence.

(ii)           Seat of the injuries and kind of weapon used by the accused.

(iii)          Position/location of the accused, the pws and the deceased, prior to the occurrence and the same during the occurrence.

(iv)         Arrival of the accused, the pws and the deceased at the place of occurrence and the ways used by them.

Sequence of cross-examination: For convenience, in criminal trial, defense counsel can divide cross-examination in certain paragraphs on the eye witness with the following sequence;

·       In first paragraph the relation of the witnesses can be asked.

        In second paragraph delay in lodging FIR can be checked.

        In third paragraph mode of occurrence and the credibility of the witnesses at the time/place can be crossed in a few mini paragraphs.

        In fourth paragraph ocular account can be confronted with medical evidence.

        In fifth paragraph motive can be checked.

        In sixth paragraph recovery witnesses can be crossed, if the eye witnesses are also the recovery witnesses.

        In seventh  paragraph defense version can be put at eye witness

        Sometime defense lawyers put their case in the beginning and it makes the thing complicated. So, the better option is to put the case of the defense at the end of the cross-examination at the complainant and the eyewitness, so that any development come into cross-examination can easily be covered up / used in defense version.

Settled principle of cross-examination.

                    If one aspect of the case is admitted by one eye witness, then no need to seek further clarification from other pws, because it’s the prosecution which has to prove and clarify its case. The job of the defense is just to create doubt. Further, if a witness gives some favorable answers, then never seek further clarification of said issue from the said pw, because normally, pw recollects his memory and clarifies the situation as already stated in favor of defense. Some time prosecution counsel makes undue interferes and tries to complicate/explain the situation and during this the witness clarifies the situation. So after seeking favorable answer change the topic and ask other question and if further clarification is needed in the favorable answer, then change the form of the question and then ask at reasonable occasion. Some time it happens that due to the wrong suggestions and questions of defense counsel the defense suffer a lot. Defense cannot get away with his suggestion and questions. So, the defense counsel is clear in mind to put questions and specially suggestions during cross-examination. The better option is that always put questions in the shape of narrations and at the end the defense version can be put in the shape of suggestions to the eye witness.

I have seen a number of times that lengthy cross-examination not only damages the defense, but some time, it becomes helpful to clarify the facts of the case which was inadvertently left by pws. It is not necessary to rebut each and every aspect of the evidence, because some evidence is produced without any relevancy. So, it is the duty of the defense to cross-examine and controvert the evidence which can be used against the defense. It is obligatory for the defense lawyers to prepare their line of cross-examination in the light of their defense, if defense is going to admit the killing while taking self-defense, like grave and sudden provocation etc, then most of the prosecution case like place/time of occurrence, identity of the accused, deceased and cause of death etc, are not required to be cross-examined in detail and in such type of situation, the stress of cross-examination should be on the mode of occurrence and the other aspects which can prove the defense version. In such type situation normally motive, medical evidence and mode of occurrence can be explained in the light of the defense. In most of the cases the comparison report of crime empties is not procured rather some time crime empties are not taken into possession by the I.O. In such a situation said recovery is totally inconsequential and cannot be used as an incriminating piece of evidence against the accused, but some time even senior defense lawyers make lengthy cross-examination on that issue. In my humble, it is totally useless practice.

          Sometime place of occurrence is not disputed, but in spite of this, defense counsel cross-examine draftsman up to a number of pages. Sometime irrelevant question are asked from formal witnesses. Said witnesses are not bound to answer such type irrelevant questions. Some questions are normally asked from the pws who identify the dead body. Mostly, they are close relatives of the deceased and they give evidence only to the identification of the dead body. Their examination-in-chief is pertaining to a few lines and defense court asks from them the time of occurrence, name of the accused and detail of mode of occurrence. If said Pw gives some answers which can favor to defense qua remaining facts of the case, then no benefit can be given to the defense. The court will only consider their evidence qua identification of the dead body and nothing else. Normally, identification of the dead body is not disputed and in such a situation, there is no need to cross-examine such type pws. However about time and place of the identification of the dead body, they can be cross-examined. So, while cross-examining, the defense lawyers, being the officers of the court should facilitate the courts and not waste the time while conducting irrelevant and lengthy cross-examination.

          Sometime complainant side insists  to produce the three pws on same point like recoveries etc, because in almost each recovery memos two pws are cited by the the I.O, it is fruitless practice and to prove recoveries only one cited  pw is required and the second one can be the I.O  of the case who prepared that recovery memo. In criminal side quality of evidence matter and even on single eye witness accused can be sentenced to death, so defence is to cross-examine said sole witness on each and every aspect of the case to falsify the occurrence. He can be cross-examined in the light of site-plan, medical evidence,motive, his own character and conduct etc, but in civil side along with quality,quantity also  matter,like article 79 Qanun-e-Shahadat Order 1984 etc.  In the same way, sometime to prove chemical or serologist or any expert   report its scribe is requested to summon as pw.This is also fruitless practice. Section 510 Cr.P.C is  clear on this point, wherein it is provided that such type reports can be used in evidence without calling it scribe. Some time defence lawyers insist that the examination-in-chief of the pws be recorded in his prersnce. Section 353 Cr.P.C  is clear on this point and only the presence of the accused is necessary at the time of recoding of evidence. If his presence is dispened with subject to appreance of his pleader, then in the presence of that pleader evidence can be recorded.The pleader can be any person including an advocate.

 

Sequence of recording of evidence:

On sequence of recording of pws, and cross examining them, no restriction can be imposed and as per article 130 Qanun-e-Shahadat order 1984, it is the discretion of the trial court, but this discretion is to be used to facilitate the fair trial. Evidence of the I.O can be recorded as Pw- 1 and evidence of complainant can be recorded as last Pw. Defense can raise objection only in the sequence of the cross-examination and not in sequence of examination-in-chief of pws. The logic behind, the sequence of the cross-examination of the pws, is that the defense has to put his case at the pws. If he will cross-examine the I.O, and complainant first, then his defense can be opened and prosecution will be in position to tutor the remaining pws especially the doctor, recovery witness and draftsman etc, in line of cross-examination as done by defense counsel on the complainant and the I.O.  Further IO, is the scribe of all the statements of pws and other proceedings, and at the end defense can cover up all his short comings while putting questions and suggestions to the IO. So, in cross-examining the pws, the sequence suggested by the defense will matter and no restriction can be imposed in sequence of recording of examination in chief. Sometime the issue of piece-meal cross-examination is raised by the defense. It is right of the defense that he will be provided opportunity to cross each of set of the witnesses, like eyewitness on one and the same day. The defense counsel cannot claim that he want to cross-examine the doctor, draftsman etc on one and the same day  along with eye-witnesses, because in such type situation, there no issue of piece meal evidence, because the evidence of said witnesses do not come under the set of witnesses.

As far as the cws are concerned, they are normally the pws and due to certain reasons prosecution, got given up them and they are summoned on request of the defense, because these types of witnesses are not supporting the prosecution case and defense want to bring their evidence on record for the corroboration of its defense, because without bringing their evidence on record, the court cannot consider the evidence of said witness as lying in police file.

In such type situation, when cws, got recorded his examination-in-chief which is normally against the prosecution, then prosecution is asked to cross-examine the cws, first because some time the defense feel no need to cross the cws. So, this is the logic for which prosecution is asked to cross-examine the cw first. So, the party against whom cws depose is asked to cross said cw.

Sometime during cross-examination pw admits that his statement under section 161 Cr.P.C was not recorded by the police. In such type situation some defense lawyer does not further cross-examine said pw, because they are of the view that said evidence of the pw cannot be used against the accused. It is wrong concept, when a pw makes his statement on oath before court of law, then it carries value in the eye of law. The previous statement i.e. 161 Cr.P.C is used for only confrontation purposes. In complaint case normally no such statements are there. In the same way sometime no such statement of cws are there, but when they make statement on oath their evidence is admissible. So, in said situation the witness must be cross-examined, otherwise his evidence can be used against the defense.

Cross-examination by a trial judge; No doubt, here in Pakistan adversarial system is in existence and a judge only got the role of umpire, but some exception are there like Art. 161 Qanun-e-Shahdat Order, 1984, section 249 A, 265 K, 340, 342, 363,539 B, and 540 Cr.P.C etc empower the trial judges to discover proper facts to do complete justice. In 2015 Pcrlj 1566 Khyzer Hayat vs judicial magistrate and 2 others, it is held that no right is available to accused to seek legal assistance at state expenses in the matters, other than entailing capital punishment. It was further held that in all others cases, it was the duty of the trial court to put a cross-examination itself on behalf of an un-represented accused, or who himself intentionally is avoiding to cross-examine the witness. When defense counsel was constantly  not showing his appearance, it was the duty of the trial court to put question itself to defend the cause of accused, or to offer accused to cross-examine the witness, in order to ascertain truth for just decision of the case.

          When the accused is represented through his counsel, then too, the court can exercise said powers, if so needed. Where an accused is not able to engage a counsel, it is the duty of the court to cross-examine witness itself on behalf of the accused. During the recording of the evidence, trial court should apply its mind to the case carefully and try to clear away any doubts created by different pieces of evidence. During the whole process of recording of the evidence the trial judge be mentally prepare and aware of the proceedings of evidence, so that he should be in a position to exercise some control in the process of recording evidence. Further if the judge himself dictates the evidence, he can better understand the worth of the pws and even make comments about demeanor of the witness in section 363 Cr.Pc.

A  trial judge  is expected  to discover the truth, therefore, if he  finds that the examination of a witness is not being conducted in such a way as  can be helpful  to reach at  just conclusion of the case, then trial judge can  intervene while making questions.  Lapse on the part of prosecution can not to be allowed to stand in the way of trial court.   Under article 161 of Qanun-e-Shahadat  order 1984 and  High court  Rules and Orders, Vol III, Chap. l-E, R.2,  the trial  Court  can  rectify the  intentional or un-intentional lapse on the part of complainant, investigating officer or complainant counsel   by calling an evidence omitted by them, on its own, if such evidence is necessary for the just decision of the case. Such powers can be exercised in the larger interest of justice. Stage of the trial is irrelevant to exercise such power and the only factor relevant for that purpose is the relevancy of the evidence called. 

So during trial, the trial judge cannot be a silent spectator and in order to discover and obtain proper proof of relevant facts of a case, trial judge is authorized to put any questions in any form without any restriction to a witness under Art. 161 of the Qanun-e-Shahadat Order 1984, particularly where police officers had shown no interest to conduct investigation in order to detect the criminals and accused were sent by them for trial without sufficient evidence. Under sections 245(1), 428, and 540 the trial court would be at liberty to receive in evidence any admissible document despite the fact that same was not annexed with report under S.173, Cr.P.C, if said document would meet the standards of admissibility, and was necessary for the just decision of the case and also would allow cross-examination thereon.

Cross-examination by prosecution / hostile witness; to understand said topic, first see what is hostile witness. According to article 150 of Qanun-e-Shahdat Order, 1984, hostile witness means a witness who while giving evidence is not interested to depose actual fact before the court and from the manner, in which he gives evidence, shows that he is not desirous of telling the truth to the court. If the witness is doing so due to certain malafide, then the court will declare him as hostile witness and the party who produced him will be allowed to cross-examine him, if so needed. Such discretion had to be exercised with due care and attention keeping in view the interests of both parties, so that no one be prejudiced from the order of the court. In order to invoke articale 150 of Qanun-e-Shahadat, 1984, it was necessary to establish that witness was guilty of equivocation or he was varying in his statement or trying to suppress the truth or that he bore animosity towards the party who called him.

          If the witness answers some questions which are in conflict with the evidence of other witnesses, then it is not the reason to declare said witness a hostile witness. Please see 2019 P Cr. L J 1475 and PLD 2019 Lahore 59.The court can declare a witness hostile at any stage of the evidence and allow the prosecution to cross-examine its own witness. Sometime a witness in his examination-in-chief fully supports his earlier statement given to the police or in the court, but in cross-examination, he starts to favour other party while contradicting his examination in chief. If his malafide is clear, then court can, during the course of his re-examination, permit the persons calling him as a witness to put questions to him which might be put in cross-examination by the adverse party. It cannot be said that if a party calling a witness is permitted to put such questions to the witness after he has been cross-examined by the adverse party, the adverse party will not have any opportunity to further cross-examine the witness on the answers so given by him. The court in exercise of its discretion will permit the adverse party to cross-examine the witness on the said answers. Please see AIR 1964 SC 1503. It is held in 2011 SCMR 23  that if the defence counsel is not co-ordinating in cross examining to  the pws and is taking undue adjournments, then the court cannot close the right of cross-examination,but provide him counsel on state expenses.  

Re-examination; If some ambiguity or confusion has arisen during the cross-examination, the party can re‑examine the witness and if some new facts have been introduced then the adverse party can cross-examine him further.The examination‑in‑chief, cross-examination and re‑examination all make one statement. The whole exercise is undertaken to extort truth so that complete justice may be dispensed with. Considering the rationale underlying article 150, the principle should be made applicable to the statement made during re‑examination as well. It is possible that during the course of re‑examination a witness while clarifying or elucidating a fact may suppress the truth or state something which appears to be palpably false or, self-contradictory or for some allied reasons then permission can be sought to cross-examine that witness.

 Cross-examination on civil side; The parameters to conduct the cross- examination in civil and criminal trial   are different in nature. In a criminal trial, time, date, place and mode of occurrence got material role in the evidence of the eye witnesses and most of the cases are based on oral evidence to that of documentary evidence and in exceptional cases documentary evidence got some importance to fix the liability in criminal cases. If there are contradictions in the above said time, date, place and mode of occurrence in the evidence of the prosecution witnesses, then normally the prosecution evidence is disbelieved and accused is acquitted, while giving him benefit of the doubt, but contradictions in time, date and place are not so important in civil trial, because civil suits are decided on the basis of preponderance of probabilities of the facts of each case.

          The rules of evidence of civil and criminal trial are almost same, but some provisions in the Qanun-e-Shahadat Order, 1984 are peculiar to criminal trial and other are peculiar to civil trial. In a civil case a mere preponderance of probabilities is a sufficient basis for decision, while in a criminal case guiltiness of the accused must be amount to such a moral certainty as persuades the mind of the court beyond all reasonable doubt and this rule as a prudence, has in fact attained the force of law, founded on public policy. There is a difference of onus of proof because in a criminal trial, it is almost on the prosecution and in exceptional circumstances, shifts to the defense, while in a civil side, it is on the party who is claiming the relief and is also determined by the court while framing issues. Criminal trial is concluded in conviction or acquittal, while in civil trial the relief sought by the plaintiff either decreed or dismissed. In civil side the burden of proof lies on the person who files a suit or proceeding to ensure his civil rights. The burden of proof as to any particular fact lies on that person who wishes the court to believe in its existence. It is apparent from articles 117 and 118  of Qanoon- shadet order 1984  that once initial onus has been discharged by the party upon whom it was resting, it would shift to the other party for its rebuttal thereof. So in civil side there is competition in both the parties to prove and disprove the stances of each others, but  in criminal trial it is visa versa.

          The criteria to prove the documents in civil and criminal trial is different to each other. In civil trial mere marking or exhibiting of documents would not dispense with requirement of proving the same and the same cannot be exhibited unless it is proved. Admitting of photocopy of a document in evidence and reading the same in evidence without observing legal requirements of Article 76 of the Qanun-e-Shahadat Order, 1984 would be illegal. Further to prove the contents of document article 79 of The Qanun-e-Shahadat Order, 1984 will matter, but said article is not so important in criminal trial.  In criminal trial maker/ scribe of the document will matter to prove the contents of the same and there is no restriction to produce two marginal witness of the same as in the case of civil trial. In civil side to prove agreement to sell etc  two marginal witnesses are necessary as per  article 79 of The Qanun-e-Shahadat Order, 1984, but the contents of  FIR  or  complaint only can be proved by the complainant  or by the scribe who wrote the FIR etc. Further there is no issue of quantity of evidence e in criminal trial like civil trial. In criminal trial only quality of evidence matter.Further please see its detail in my  article published in PLJ November 2022 page 97.

 

         

By, Malik Munir Ahmed Joyia.

District &sessions judge.

Banking court no 5 Lahore.   

Malikmunir9014@g.mail .

                             03039466323-03466249001

 


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