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"9. We fail to appreciate
as to which law permits such a thing
and how a Judge of standing of
Additional Sessions Judge could do
Patna High Court CR. APP (SJ) No.422 of 2004 dt.06-05-2026
such a thing. First thing we must
notice that P.W.9 is an Assistant to
an Advocate Clerk, who has nothing
to do with the case, yet the Court
permits him to step in as a
prosecution witness. Moreover we
have coined such witness as "Sankat
Mochan witness". What more
scandalized us is the trial court,
which permits a person, who was
nobody, to pick up the entire case
diary from paragraphs 1 to 121 and
prove it and make it a part of
evidence. The court then proceeds
further to mark it as Ext. 3 and then
the court sits down to read entire
case-diary in order to appreciate
evidence. Nothing can be more
scandalous. No such step is
permissible in law. The trial court
forgot the true import of section
172(2) of the Code of Criminal
Procedure (for short 'Cr.P.C.'), which
clearly states that any criminal Court
may use such diaries, not as
evidence in the case, but to aid it in
such enquiry or trial. What the trial
court has done is using it as
evidence, making it as evidence and
Patna High Court CR. APP (SJ) No.422 of 2004 dt.06-05-2026
appreciating it as evidence, which is
wholly impermissible in law. The
diary can never be proved in a
Court, for it cannot be used as
evidence. No part of diary can be
proved because if any one is proving
it for the purposes of making it an
evidence, such act is prohibited by
law. The law contemplates a
reference to the diary only for the
purposes of refreshing memory or
contradicting the statements of
witnesses in the Court with the
statements made during the course
of investigation. Only when it is used
for refreshing memory, the
procedure as envisaged under
section 145 of the Evidence Act is to
apply but that does not mean that
diary can become evidence. Law
prohibits such thing. We have found
in cases after cases that in the State
of Bihar, the Sessions Courts do not
know or understand this distinction
in law and in cases after cases the
statements of witnesses recorded
under section 161 of the Cr.P.C. are
proved as evidences or other
materials in the case-diary are
Patna High Court CR. APP (SJ) No.422 of 2004 dt.06-05-2026
proved as evidence and marked as
exhibits. This is a practice that
should end, the sooner the better.
The other thing is that as to who is
permitted to prove a document. It
appears that in this State every Tom,
Dick and Harry, the expression we
have formed now "Sankat Mochan
Witness", could come and prove any
official document. In this case, an
Assistant to Clerk of an Advocate,
who has nothing to do in the case,
has been permitted by the trial court
to prove the entire case-diary and
mark it as exhibit. This practice is
deprecated and it must come to an
end. A person, who is author of a
document or in absence of author,
which absence has to be explained,
a person familiar with the
handwriting of the author can only
prove the document. The procedure
adopted by the trial court is
unknown to law. No sooner this
practice ends than better it would
be."