A) ABSTRACT / HEADNOTE

The landmark judgment in Macherla Hanumantha Rao and Others v. The State of Andhra Pradesh (1958 SCR 396) addressed the constitutional validity of Sections 207 and 207A of the Code of Criminal Procedure, 1898, introduced by the Amendment Act 26 of 1955. The appellants were committed to the Court of Session under proceedings initiated on a police report, where the magistrate adopted the procedure prescribed in Section 207A. The challenge rested on the argument that these provisions violated the guarantee of equality before the law under Article 14 of the Constitution, due to their differential treatment of accused persons based on the mode of case institution—i.e., whether initiated on a police report or a private complaint. The Supreme Court upheld the constitutional validity of these provisions. The Court concluded that although the procedures differed, they did not affect the fairness of the trial, and the classification served a legitimate objective of expediting the trial process. Drawing from a spectrum of prior decisions, including Budhan Choudhry v. State of Bihar (1955 SCR 1045), the Court found that the classification was reasonable and non-arbitrary, and did not offend Article 14. The appeal was thus dismissed.

Keywords: Section 207A CrPC, Article 14 Constitution, Equality before law, Commitment procedure, Discrimination, Speedy trial

B) CASE DETAILS

i) Judgement Cause Title: Macherla Hanumantha Rao and Others v. The State of Andhra Pradesh

ii) Case Number: Criminal Appeal No. 57 of 1957 and Criminal Misc. Petition No. 294 of 1957

iii) Judgement Date: 17 September 1957

iv) Court: Supreme Court of India

v) Quorum: S.R. Das C.J., Venkatarama Ayyar, B.P. Sinha, J.L. Kapur, A. Sarkar, JJ.

vi) Author: B.P. Sinha, J.

vii) Citation: 1958 SCR 396

viii) Legal Provisions Involved:

• Section 207 & 207A, Code of Criminal Procedure, 1898 (as amended by Act 26 of 1955)

• Article 14, Constitution of India

• Sections 147, 148, 323, 324, 302 read with 34 and 149, Indian Penal Code

ix) Judgments overruled by the Case (if any): None

x) Case is Related to which Law Subjects:
Criminal Law, Constitutional Law, Criminal Procedure, Equality Jurisprudence

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

This case revolves around the constitutional challenge posed against newly introduced procedural amendments to the Code of Criminal Procedure under the 1955 Amendment Act. Specifically, it targeted Section 207A, which streamlined the commitment procedure for cases instituted on police reports, compared to the older procedure under Section 208 for cases started on private complaints. The appellants, accused of serious crimes including rioting and murder, were committed under the newer procedure. They contended that this classification was unconstitutional, creating unequal treatment based solely on the procedural source. The case is significant as it tested the bounds of Article 14 in criminal procedural law, juxtaposing equality before law against legislative classification for efficiency.

D) FACTS OF THE CASE

On 22 December 1955, a serious incident of rioting and murder occurred, prompting a police investigation. Based on the evidence gathered, a charge-sheet was submitted against 26 accused persons, including Macherla Hanumantha Rao. The Magistrate, acting under Section 207A, committed them to the Sessions Court at Guntur. The accused challenged the legality of this commitment on the grounds that Section 207A created discrimination, since accused persons in similar offences but initiated via private complaints enjoyed greater procedural protections under Section 208. They argued this denied them equality before law, and sought quashing of the commitment under Sections 435 and 439 CrPC. The Andhra High Court, however, rejected the claim, leading to this appeal before the Supreme Court, certified under Article 134(1)(c).

E) LEGAL ISSUES RAISED

i) Whether Sections 207 and 207A of the Code of Criminal Procedure, 1898, as amended by Act 26 of 1955, violate Article 14 of the Constitution by prescribing different commitment procedures for police-report-initiated cases and complaint-based cases?

F) PETITIONER/ APPELLANT’S ARGUMENTS

i) The counsels for Petitioner / Appellant submitted that Section 207A provided lesser procedural safeguards to accused persons than Section 208, thereby creating an arbitrary classification. For example, they highlighted that:

• Under Section 208(3), accused persons could compel the attendance of their own witnesses. But under Section 207A(2), this power was only conferred on the prosecution.

• Section 208(1) permitted recording of evidence for both parties, while Section 207A(4) confined it to prosecution witnesses.

• Section 209(2) and Section 213(2) allowed for discharge of the accused; but no such parallel existed in Section 207A.

• The standard for discharge under Section 207A(6) used the phrase “no grounds” unlike the “not sufficient grounds” in Section 209(1).
  These disparities were argued to cumulatively result in hostile discrimination, especially since both sets of accused faced similar criminal charges, thereby infringing Article 14.

G) RESPONDENT’S ARGUMENTS

i) The counsels for Respondent submitted that the object of the classification under Section 207A was to ensure swift justice in cases where the State machinery had already undertaken a thorough police investigation. The discretion to differentiate between cases initiated via police report versus complaint was a valid legislative policy, not arbitrary. They argued that:

• The trial procedure remained the same post-commitment for both classes.

• The pre-trial stage merely required a different route for committal, which was reasonably connected to the object of expediting trials.

• The classification was based on intelligible differentia, i.e., prior investigation by a responsible public official, and not on any irrelevant ground.
  They relied on Budhan Choudhry v. State of Bihar, (1955) SCR 1045, where differential procedural rules based on local jurisdiction were upheld as non-violative of Article 14.

H) RELATED LEGAL PROVISIONS

i)

• Section 207 CrPC (1898): Provision to supply documents to accused in cases instituted on a police report

• Section 207A CrPC (1898): Introduced commitment procedure for police-report cases

• Section 208 CrPC (1898): Commitment procedure for complaint cases

• Article 14, Constitution of India: Equality before law and equal protection of laws

• Sections 147, 148, 323, 324, 302 r/w 34 and 149, Indian Penal Code: Charges for rioting and murder with common intention and unlawful assembly

I) JUDGEMENT

a. RATIO DECIDENDI

i) The Court upheld the constitutional validity of Sections 207 and 207A CrPC, holding that the classification between cases based on whether they are instituted on police report or private complaint is rational and non-arbitrary. The differentiation is based on whether a prior official investigation has been conducted, and the Legislature’s intention to expedite proceedings in cases with established police scrutiny. The Court emphasized that there was no prejudice to the accused at the trial stage, which remained uniform irrespective of the commitment route. Hence, Article 14 was not infringed.

b. OBITER DICTA

i) The Court remarked that efficiency in criminal justice is a legitimate legislative goal, and minor procedural variances at the pre-trial stage do not amount to discriminatory treatment. The judgment also noted that delay in trials often harms accused persons, particularly those who are innocent, and a summary pre-trial helps avoid prolonged incarceration or stigma.

c. GUIDELINES 

None specific. However, the Court implicitly recognized the following:

• Police-report-based proceedings can follow a more streamlined commitment procedure.

• Article 14 allows for reasonable classification if backed by intelligible differentia and legitimate objective.

• The pre-trial stage can be tailored differently if post-commitment trial rights remain unaltered.

I) CONCLUSION & COMMENTS

The Supreme Court’s affirmation of Sections 207 and 207A CrPC in this judgment fortified the principle that Article 14 does not mandate absolute uniformity, but permits rational classification. The ruling validated the State’s power to differentiate procedures based on prior official action such as police investigation. The Court took a pragmatic approach, recognizing that procedural efficiency and justice delivery go hand in hand. The judgment remains crucial in criminal procedural jurisprudence, especially in delineating the scope of Article 14 vis-à-vis procedural laws. It also provided legislative backing to the streamlining of committal processes, and became an enduring precedent on the reasonableness of legislative classifications.

J) REFERENCES

a. Important Cases Referred
i) Budhan Choudhry v. State of Bihar, [1955] SCR 1045
ii) Matajog Dobey v. H.C. Bhari, [1955] 2 SCR 925
iii) Chiranjit Lal Chowdhury v. Union of India, [1950] SCR 869
iv) State of Bombay v. F.N. Balsara, [1951] SCR 682
v) State of West Bengal v. Anwar Ali Sarkar, [1952] SCR 284
vi) Kathi Raning Rawat v. State of Saurashtra, [1952] SCR 435
vii) Lachmandas Kewalram Ahuja v. State of Bombay, [1952] SCR 710
viii) Qasim Razvi v. State of Hyderabad, [1953] SCR 581
ix) Habeeb Mohammad v. State of Hyderabad, [1953] SCR 661
x) State of Punjab v. Ajaib Singh, [1953] SCR 254

b. Important Statutes Referred
i) Code of Criminal Procedure, 1898, Sections 207, 207A, 208, 209, 213
ii) Indian Penal Code, Sections 147, 148, 323, 324, 302, 34, 149
iii) Constitution of India, Article 14