FACTS: On 15th April 2003, Jai Singh, SI (PW-27) from the Sector-5, Panchkula police station, received information about a gang involved in kidnapping children for ransom in Panchkula. The information indicated that a similar incident had occurred at Kothi No. 81-A, Sector 17, Panchkula. Jai Singh forwarded this information, leading to the registration of FIR No. 283 of 2003. The appellants were tried and convicted under Sections 364A, 392, and 120B IPC by the Additional Sessions Judge. They appealed the convictions to the Punjab and Haryana High Court, which dismissed their appeals.

ISSUE: Can a trial court act as a mere spectator in a trial, or is it required to actively elicit relevant evidence?

OBSERVATION: The Court held that trial courts must actively ensure that all relevant evidence is presented to achieve a just outcome. Under Section 311 CrPC and Section 165 of the Evidence Act, it is the court’s duty to call necessary witnesses and examine evidence, even if a party fails to present it. In this case, the trial court's failure to summon and examine a crucial witness, Shamlal Garg, compromised the fairness of the trial. Consequently, the Court gave the benefit of the doubt to the appellants due to the inadequate examination of key evidence. The appeals were allowed, and the appellants were acquitted of the kidnapping and abduction charges.