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Saturday, May 25

Pre-trial detention can not be setoff against sentence under Court-martial

Samrendra Beura vs. U.O.I. & others, Writ Petition (Crl.) No. 78 of 2013, Decided on May 20, 2013


Court-martial proceeding. The Accused found guilty of the offence under Section 39(a) of the Air Force Act, 1950

Accused claimed setting off the pre-trail detention. The Hon’ble Supreme Court held:

“there can be no scintilla of doubt that the pre-trial detention cannot be set off against the sentence of imprisonment passed by the court-martial for the offence under Section 39(a) which has been affirmed under Section 161(1) of the Act and the period of sentence shall commence from the date when the original proceeding was signed by the Presiding Officer.” [Para 12]

The Court noted following case laws:

Ajmer Singh and others v. Union of India and others, (1987) 3 SCC 340, the issue before this Court was regarding the applicability of Section 428 of the Code of Criminal Procedure to a person sentenced to undergo imprisonment by general court-martial under the Army Act, 1950 (for short “the 1950 Act”). The two learned Judges observed that the position in the Army Act would equally govern the person sentenced to undergo rigorous imprisonment by the court martial under the Navy Act, 1957 (for short “the 1957 Act”) and the Air Force Act. The two-Judge Bench referred to the divergence of views between different High Courts pertaining to the applicability of Section 428 of the Code and, thereafter, the interpreted Section 167 of the 1950 Act and came to hold as follows: -


“9. Section 167 of the Act specifically lays down that whenever a person is sentenced by a court martial under the Act to imprisonment, the term of his sentence shall, whether it has been revised or not, be reckoned to commence on the day on which the original proceedings were signed by the Presiding Officer or, in the case of a summary court martial, by the Court. In the face of this categorical provision laying down that the sentence of imprisonment shall be deemed to have commenced only on the day when the court martial proceeding was signed by the Presiding Officer or by the Court as the case may be, it is in our opinion futile to contend that the Army Act is silent with respect to the topic as to the date with effect from which the period of imprisonment covered by the sentence is to be reckoned. We state this only for the reason that an ingenious argument was advanced before us by counsel for the appellants that Section 5 of the Code of Criminal Procedure only lays down that nothing in the Code shall affect any special or local law and hence in the absence of any specific provision in the special or local law covering the particular subject-matter, the provisions of the Code would get attracted. Even if this argument is to be assumed to be correct (which assumption we shall presently show is wholly unwarranted), inasmuch as Section 167 of the Act specifically deals with the topic of the date of commencement of the sentence of imprisonment, there is absolutely no scope for invoking the aid of Section 428 of the Code of Criminal Procedure in respect of prisoners convicted by court martial under the Act.”


Bhuwaneshwar Singh v. Union of India and Others (1993) 4 SCC 327, the Court referred to the pronouncement in Ajmer Singh case and opined that as far as set off of the period of pre-trial detention against the period of sentence is concerned, Section 428 of the Code is not attracted to the cases of persons convicted by the court-martial to undergo imprisonments.


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