Aejaz Ahmad Sheikh vs State of Uttar Pradesh 2025 case drew attention due to its horrific facts where an entire family was wiped out in a suspected act of domestic violence. It gained legal significance because the Supreme Court used it to highlight frequent lapses in criminal trial procedures specifically, the improper or incomplete recording of the accused's statement under Section 313 CrPC. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Aejaz Ahmad Sheikh vs State of Uttar Pradesh 2025 Introduction

The case of Aejaz Ahmad Sheikh vs State of Uttar Pradesh 2025 revolves around the brutal death of Amina, her three daughters and a cousin allegedly caused by Hasim Sheikh who was accused of setting them ablaze. Initially sentenced to death by the Trial Court, the accused Hasim was later acquitted by the High Court. The matter was brought before the Supreme Court, raising critical procedural concerns regarding compliance with Section 313 CrPC and the fair conduct of criminal trials.

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The case at hand centres around the brutal death of Amina, her three daughters and the accused's cousin Aslam, all due to burn injuries allegedly inflicted by Hasim Sheikh. The incident, marked by gruesome violence within the family which led to the accused being initially convicted and sentenced to death by the Trial Court. However, the High Court later acquitted him and prompted the State and the complainant to file appeals before the Supreme Court. The following are the facts of Aejaz Ahmad Sheikh vs State of Uttar Pradesh -

Gruesome Incident and Deaths

The case originated from the judgment of the High Court which acquitted Hasim Sheikh, accused of killing his wife, three daughters and cousin by setting them on fire. The tragic incident involved gruesome burn injuries leading to multiple deaths.

• Hasim Sheikh was charged under Section 302 of Indian Penal Code for the murder of family members.
• Victims included Amina (wife), Najma, Fatima, Salma (daughters) and Aslam (cousin).
• The deaths were caused by severe burn injuries.

Background of the Victims and the Complaint

The accused, Hasim Sheikh and his wife Amina had five children. PW-1, Aejaz Ahmad Sheikh, Amina’s brother filed the complaint after witnessing ongoing abuse in the family.

• Hasim and Amina had three daughters and two sons: Najma, Fatima, Salma, Kamar Hasim, and Kadam.
• PW-1 visited the accused's house on 26th December, 2008 to resolve domestic issues.
• Amina pleaded with PW-1 not to leave and feared a threat to her life.

Incident Leading to the Deaths

Shortly after PW-1’s departure, a catastrophic incident happened where the accused and his cousin allegedly set Amina and her daughters on fire using kerosene.

• PW-1 received a call informing him about the incident hours after his visit.
• Najma died immediately at the scene due to burn injuries.
• Amina, Fatima and Salma were admitted to the District Hospital in critical condition.

Dying Declarations

The dying declarations of the victims played an important role in the case and was recorded by Tahsildar Harish Chandra Singh (PW-11) on the same day of the incident.

• Fatima stated her father and villagers poured kerosene and set them on fire and blamed her grandparents.
• Amina declared that the accused locked them inside, poured kerosene and lit the fire.
• These statements were essential pieces of evidence against the accused.

Registration of FIR and Investigation

Following the incident the police initiated criminal proceedings based on PW-1’s complaint which led to the registration of First Information Report and subsequent investigation.

• FIR was registered on 26th December 2008 under Section 302, Section 307 and Section 120B of Indian Penal Code.
• Burnt clothes and a plastic can with 100 grams of kerosene were recovered from the crime scene.
• Salma died on 1st January, 2009, Aslam and Fatima died on 2nd January, 2009 and Amina died on 6th January, 2009 due to burn injuries.

Conviction by the Trial Court

The Trial Court, after carefully examining the evidence, convicted Hasim Sheikh of murder and imposed the death penalty. The Trial Court considered the brutality of the crime.

• The court relied on the testimony of PW-5 (minor son Kamar Hasim) and dying declarations.
• Hasim Sheikh was convicted on 19th April, 2014.
• The case was classified as “rarest of the rare,” warranting capital punishment.

Acquittal by the High Court

The High Court acquitted Hasim Sheikh despite the judgment of the Trial Court. The High Court refused to uphold the death penalty or any conviction under Section 302 of Indian Penal Code.

• The High Court refused to confirm the death sentence.
• It proceeded to acquit the accused completely.

Appeals before the Supreme Court

Aggrieved by the acquittal granted by the High Court, the State and PW-1 filed appeals before the Supreme Court seeking justice for the deceased victims.

• Criminal Appeal Nos. 2143-44 of 2017 were filed by the State.
• Criminal Appeal No. 2142 of 2017 was filed by PW-1.
• The Supreme Court appointed Shri Shubhranshu Padhi as Amicus Curiae to represent PW-1.

Aejaz Ahmad Sheikh vs State of Uttar Pradesh 2025 Legal Issues

The case Aejaz Ahmad Sheikh vs State of Uttar Pradesh 2025 addressed various important legal issues related to the procedural aspects regarding the rights of the accused and the conduct of criminal trials. The following issues were considered-

1. Non-compliance with Section 313 of Criminal Procedure Code

• Issue: The Supreme Court examined whether the failure to present vital prosecution evidence to the accused during their statement under Section 313 of Criminal Procedure Code can affect the fairness of the trial and lead to acquittals?
• Legal Importance: Section 313 of Criminal Procedure Code ensures that the accused has the opportunity to respond to the allegations against them by explaining any incriminating evidence presented during the trial. Failure to comply with this provision can result in a miscarriage of justice.

2. Proactive Role of High Courts in Criminal Appeals

• Issue: The Supreme Court in Aejaz Ahmad Sheikh vs State of Uttar Pradesh examined whether the High Courts should take a proactive approach in ensuring compliance with Section 313 of Criminal Procedure Code at the outset of criminal appeals to prevent wrongful acquittals or delays?
• Legal Importance: The Court highlighted that High Courts must immediately check if the accused's statement under Section 313 was properly recorded and, if necessary, remand the case to the trial court to correct any procedural defects.

3. Impact of Delays in Correcting Section 313 Defects

• Issue: The Court also considered whether defects in recording the Section 313 statement, if not identified and rectified in time could become irreversible due to the lapse of time?
• Legal Importance: The Court noted that such delays could prevent the rectification of errors, leading to the possibility of wrongful acquittals and preventing the accused from being fairly tried.

Section 315 of Criminal Procedure Code played an important role in Aejaz Ahmad Sheikh vs State of Uttar Pradesh 2025. The following is the analysis of this provision:

Section 313 of the Criminal Procedure Code (CrPC)

Section 313 of Criminal Procedure Code (Now Section 351 of Bharatiya Nagarik Suraksha Sanhita, 2023) mandates that during a trial, the accused must be given the opportunity to personally explain any evidence or circumstances against them that are brought up by the prosecution. The objective is to ensure that the accused can respond to the evidence and allegations presented.
The Aejaz Ahmad Sheikh vs State of Uttar Pradesh case revolves around the failure to comply with Section 313 CrPC, where the accused was not given a chance to explain the vital prosecution evidence during the trial.

Aejaz Ahmad Sheikh vs State of Uttar Pradesh 2025 Judgment and Impact

On 22nd April, 2025, the Supreme Court of India in Aejaz Ahmad Sheikh vs State of Uttar Pradesh acknowledged the issue of acquittals in criminal cases due to violations of Section 313 of Code of Criminal Procedure (CrPC). The 3-Judge Bench of the Supreme Court comprising Justice Abhay S. Oka, Justice Pankaj Mithal and Justice Ahsanuddin Amanullah highlighted the importance of ensuring that vital prosecution evidence is presented to the accused, providing them an opportunity to explain the allegations against them. The following is a detailed account of the observations and recommendations of the Supreme Court.

Supreme Court Flags Concern Over Acquittals Due to Section 313 CrPC Violations

The Supreme Court in Aejaz Ahmad Sheikh vs State of Uttar Pradesh raised serious concerns about acquittals in criminal cases where important prosecution evidence was not presented to the accused, denying them the opportunity to respond to the allegations made against them.

Supreme Court Recommendation: Proactive Approach by High Courts

To address this procedural lapse, the Supreme Court recommended that High Courts adopt a proactive stance. It suggested that at the very beginning of criminal appeals, the High Courts must verify compliance with Section 313 of Code of Criminal Procedure. In case of any defects, they should promptly remand the matter to the trial court for rectification.

Objective: Conserving Judicial Time and Avoiding Future Prejudice

The Supreme Court in Aejaz Ahmad Sheikh vs State of Uttar Pradesh highlighted that such early intervention would conserve judicial time and eliminate later claims by the accused that they were prejudiced by not being allowed to respond to incriminating evidence. The Court also noted that a significant lapse of time renders this defect incurable which makes it impractical to remand the matter years later just to correct Section 313 statements.

Supreme Court Observation on Frequent Defaults

The Supreme Court remarked in Aejaz Ahmad Sheikh vs State of Uttar Pradesh:

“Several criminal appeals come before us where we find that vital prosecution evidence was not put to the accused during their Section 313 CrPC statement. Due to the long lapse of time, the Court becomes helpless, and the defect cannot be cured by remanding the matter."

Proposed Solution: Immediate Examination of Section 313 Compliance

The Supreme Court ordered that when an appeal against conviction reaches the High Court, it must immediately examine whether the statement of the accused under Section 313 CrPC (now Section 351 of the Bharatiya Nagarik Suraksha Sanhita, 2023) was properly recorded.
In case of any defects, the High Court can either:

• Record the further statement itself
• Direct the trial court to record the statement

Implementing this approach, the Supreme Court said it would prevent the accused from raising arguments of delay and prejudice at a later stage.

Aejaz Ahmad Sheikh vs State of Uttar Pradesh Case Supreme Court Final Decision

The Supreme Court noted the accused’s argument on the face of it persuasive, it upheld the acquittal granted by the High Court. The Court observed that the High Court had acquitted the accused based not merely on Section 313 of CrPC violations but also on other substantive discrepancies such as the inadmissibility of the dying declaration.

Further Directions in the Aejaz Ahmad Sheikh Case

The Supreme Court in Aejaz Ahmad Sheikh vs State of Uttar Pradesh also directed Judicial Academies to train judicial officers to avoid the frequent omission of recording Section 313 statements properly. It advised trial judges handling cases with numerous prosecution witnesses to utilize Section 313(5) CrPC, which allows written questionnaires, thereby minimizing errors and omissions.

Conclusion

In Aejaz Ahmad Sheikh vs State of Uttar Pradesh 2025 the Supreme Court on 22nd April, 2025, upheld the acquittal granted by the High Court. The Court highlighted the need for urgent reforms in trial procedures. It urged High Courts to proactively verify Section 313 compliance at the appellate stage and recommended judicial training to address such procedural lapses.