Ranveer Singh Alias Ranveer Bijarnia, S/o. Madan Lal v. State Of Rajasthan, Through Secretary
2026-02-11
FARJAND ALI
body2026
DigiLaw.ai
ORDER : FARJAND ALI, J. 1. The instant criminal writ petition has been instituted under Article 226 of the Constitution of India by the petitioners, inter alia, seeking indulgence of this Court for issuance of appropriate directions permitting them to attend and participate in all criminal trials pending against them through the mode of video conferencing. 2. The petitioners, who are stated to be connected with certain business entities including Nexa Evergreen Energy, are facing more than 100 FIRs registered in different districts of Rajasthan in relation to alleged investment and real estate transactions. Some matters have culminated in charge-sheets and trials are underway, while others remain under investigation. Owing to successive arrests, police custody in multiple cases, and the multiplicity of proceedings in different jurisdictions, the petitioners submit that their physical attendance in each trial is causing grave hardship and serious prejudice, necessitating indulgence of this Court. 3. Heard learned counsel appearing on behalf of the petitioners as well as learned Deputy Government Advocate and perused the material available on record. 4. Before adverting to the practical difficulties that may arise in cases where an accused is implicated in hundreds of FIRs, this Court deems it appropriate to first examine the statutory framework governing appearance through video conferencing. The Video Conferencing Rules, notified vide G.S.R. 311 dated 13th May, 2021 (hereinafter to be referred as “VC Rules”), lay down comprehensive provisions regulating the conduct of proceedings through virtual mode. The said Rules, inter alia, prescribe the general principles governing video conferencing and also delineate the procedure relating to applications for appearance, recording of evidence, and submissions through video conferencing. For ready reference and proper appreciation, the relevant provisions are reproduced hereinbelow:- 3. General Principles Governing Video Conferencing (i) Video conferencing facilities may be be used at all stages of judicial proceedings and proceedings conducted by the Court. (ii) All proceedings conducted a Court by way of video conferencing shall be judicial proceedings and all the courtesies and protocols applicable to a physical Court shall 4 apply to these virtual proceedings. The protocol provided in Schedule I shall be adhered to for proceedings conducted by way of video conferencing.
(ii) All proceedings conducted a Court by way of video conferencing shall be judicial proceedings and all the courtesies and protocols applicable to a physical Court shall 4 apply to these virtual proceedings. The protocol provided in Schedule I shall be adhered to for proceedings conducted by way of video conferencing. (iii) All relevant statutory provisions applicable to judicial proceedings including provisions of the CPC, CrPC, Contempt of Courts Act, 1971, Indian Evidence Act, 1872 ( abbreviated hereafter as the Evidence Act), and Information Technology Act, 2000 (abbreviated hereafter as the IT Act), shall apply to proceedings conducted by video conferencing. (iv) Subject to maintaining independence, impartiality and credibility of judicial proceedings, and subject to such directions as the High Court may issue, Courts may adopt such technological advances as may become available from time to time. (v) The Rules as applicable to a Court shall mutatis mutandis apply to a Commissioner appointed by the Court to record evidence and to an inquiry officer conducting an inquiry. (vi) There shall be no unauthorised recording of the proceedings by any person or entity. (vii) The person defined in Rule 2(xii) shall provide identity proof as recognised by the Government of India/State Government/Union Territory to the Court point coordinator via personal email. In case identity proof is not readily available the person concerned shall furnish the following personal details: name, parentage and permanent address, as also, temporary address if any. SCHEDULE I 1. All participants shall wear sober attire consistent with the dignity of the proceedings. Advocates shall be appropriately dressed in professional attire prescribed under the Advocates Act, 1961. Police officials shall appear in the uniform prescribed for police officials under the relevant statute or orders. The attire for judicial officers and Court staff will be as specified in the relevant rules prescribed in that behalf by the High Court. The decision of the Presiding Judge or officer as to the dress code will be final. 2. Proceedings shall be conducted at the appointed date and time. Punctuality shall be scrupulously observed. 3. The case will be called out and appearances shall be recorded on the direction of the Court. 4. Every participant shall adhere to the courtesies and protocol that are followed in a physical Court. Judges will be addressed as “Madam/Sir” or “Your Honour”. Officers will be addressed by their designation such as “Bench Officer/Court Master”.
3. The case will be called out and appearances shall be recorded on the direction of the Court. 4. Every participant shall adhere to the courtesies and protocol that are followed in a physical Court. Judges will be addressed as “Madam/Sir” or “Your Honour”. Officers will be addressed by their designation such as “Bench Officer/Court Master”. Advocates will be addressed as “Learned Counsel/Senior Counsel” 5. Advocates, Required Persons, parties in person and other participants shall keep their microphones muted till such time as they are called upon to make submissions. 6. Remote Users shall ensure that their devices are free from malware. 7. Remote Users and the Coordinator at the Remote Point shall ensure that the Remote Point is situated in a quiet location, is properly secured and has sufficient internet coverage. Any unwarranted disturbance caused during video conferencing may if the Presiding Judge so directs render the proceedings non-est. 8. All participants’ cell phones shall remain switched off or in air-plane mode during the proceedings. 9. All participants should endeavour to look into the camera, remain attentive and not engage in any other activity during the course of the proceedings A plain reading of Rule 3 of the VC Rules, makes the legislative intent abundantly clear. Rule 3(i) unequivocally provides that video conferencing facilities may be utilised at all stages of judicial proceedings and in all proceedings conducted by the Court. Thus, the permissibility of conducting proceedings through virtual mode is not confined to any particular stage but extends comprehensively to the entirety of the judicial process. Further, Rule 3(ii) mandates that all proceedings conducted by way of video conferencing shall be deemed to be judicial proceedings in the eyes of law. Consequently, every such proceeding carries the same sanctity, seriousness, and legal consequences as proceedings conducted in a physical courtroom. The Rule further stipulates that all courtesies, decorum, and established protocols applicable to physical court proceedings shall equally govern virtual hearings. In addition thereto, strict adherence to the protocol prescribed in Schedule I is made mandatory for proceedings conducted through video conferencing. Therefore, the statutory scheme leaves no room for ambiguity, proceedings conducted via video conferencing are not an exception or deviation from regular judicial process, but are fully recognised judicial proceedings, to be conducted in conformity with the prescribed protocol and with due observance of all applicable procedural safeguards. 5.
Therefore, the statutory scheme leaves no room for ambiguity, proceedings conducted via video conferencing are not an exception or deviation from regular judicial process, but are fully recognised judicial proceedings, to be conducted in conformity with the prescribed protocol and with due observance of all applicable procedural safeguards. 5. Having considered the general principles governing proceedings through video conferencing, this Court now proceeds to examine Rule 6 of the VC Rules, which delineates the procedure relating to appearance, recording of evidence, and submissions through video conferencing. Rule 6 specifically provides the mechanism and modalities to be followed where a party seeks to appear, lead evidence, or advance submissions by way of video conferencing. The said provision ensures that such participation is not left to unguided discretion, but is regulated in accordance with a structured procedural framework consistent with the administration of justice. For ease of reference and proper appreciation, the relevant rule is reproduced hereinbelow:- 6. Application for Appearance, Evidence and Submission by Video Conferencing: 6.1 Any party to the proceeding or witness, save and except where proceedings are initiated at the instance of the Court, may move a request for video conferencing. A party or witness seeking a video conferencing proceeding shall do so by making a request in the form prescribed in Schedule II. 6.2 Any proposal to move a request to for video conferencing should first be discussed with the other party or parties to the proceeding, except where it is not possible or inappropriate, for example in cases such as urgent applications. 6.3 On receipt of such a request and upon hearing all concerned persons, the Court will pass an appropriate order after ascertaining that the application is not filed with an intention to impede a fair trial or to delay the proceedings. 6.4 While allowing a request for video conferencing, the Court may also fix the schedule for convening the video conferencing. 6.5 In case the video conferencing event is convened for making oral submissions, the order may require the Advocate or party in person to submit written arguments and precedents, if any, in advance on the official email ID of the concerned Court. 6.6 Costs, if directed to be paid, shall be deposited within the prescribed time, commencing from the date on which the order convening proceedings through video conferencing is received. SCHEDULE II Request Form for Video Conference 1.
6.6 Costs, if directed to be paid, shall be deposited within the prescribed time, commencing from the date on which the order convening proceedings through video conferencing is received. SCHEDULE II Request Form for Video Conference 1. Case Number / CNR Number (if any) 2. Cause Title 3. Proposed Date of conference (DD/MM/YYYY):___________ 4. Location of the Court Point(s):______________ 5. Location of the Remote Point(s):_______________________ 6. Names & Designation of the Participants at the Remote Point: ___________________ 7. Reasons for Video Conferencing: In the matter of: 8. Nature of Proceedings: Final Hearing Motion Hearing Others I have read and understood the provisions of Rules for Video Conferencing for Courts (hyperlink). I undertake to remain bound by the same to the extent applicable to me. I agree to pay video conferencing charges if so, directed by the Court. Signature of the applicant/authorised signatory: Date: For use of the Registry / Court Point Coordinator A) Bench assigned: B) Hearing: Held on (DD/MM/YYYY): Commencement Time: End time: Number of hours: C) Costs: Overseas transmission charges if any: To be Incurred by Applicant /Respondent: To be shared equally: Waived; as ordered by the Court: Signature of the authorised officer: Date: Upon a bare perusal of Rule 6 of the VC Rules read with Schedule II appended thereto, it becomes manifest that a specific procedure has already been prescribed for submitting an application seeking permission for appearance, leading of evidence, or making submissions through video conferencing. Schedule II provides the format in which such an application is required to be moved before the competent Court. However, in the peculiar facts of the present case, the petitioners are stated to be arrayed as accused in hundreds of FIRs, giving rise to multiple proceedings pending before different Courts. In such circumstances, insistence upon filing separate and individual applications in the prescribed format in each and every proceeding would not only result in multiplicity of procedural compliances but would also render the process unduly onerous and impracticable.
In such circumstances, insistence upon filing separate and individual applications in the prescribed format in each and every proceeding would not only result in multiplicity of procedural compliances but would also render the process unduly onerous and impracticable. Having regard to the object and spirit of the VC Rules, namely, to facilitate access to justice and ensure expeditious conduct of proceedings through technological means, this Court deems it appropriate, in exercise of its supervisory jurisdiction, to issue necessary directions permitting the petitioners to appear through video conferencing in all the pending trials arising out of the FIRs in question, subject, of course, to compliance with the safeguards and protocol prescribed under the Rules. 6. Moving on to the practical difficulties that may arise in cases where an accused is implicated in hundreds of FIRs. After perusing the material available on record and anxious consideration of the peculiar factual conspectus of the present matter, this Court deems it appropriate to record certain observations with respect to the systemic implications of repeated inter-State custodial production, particularly where multiple proceedings arise out of a common transactional framework:- I. Institutional Strain on the Law-Enforcement Machinery It is evident that each inter-State custodial production requires constitution of an escort contingent, often comprising several police officials including armed personnel. Such deployment necessarily disengages officers from their regular law-and-order duties, investigative assignments and public service functions for extended durations. When such productions become recurrent across numerous jurisdictions, the cumulative diversion of manpower imposes a tangible strain upon the policing structure of the State, affecting administrative equilibrium and operational efficiency. II. Recurring Drain on Public Resources Custodial transit across State boundaries entails expenditure towards official vehicles, fuel, toll charges, daily allowances, boarding arrangements and ancillary security logistics. In matters involving multiple cases springing from a common set of allegations, repeated physical transfers result in recurring and escalating financial outflow from the public exchequer. Where secure Video Conferencing infrastructure is available, such repeated expenditure may not be commensurate with the procedural objective sought to be achieved. III. Procedural Congestion and Inter-Jurisdictional Complexities The mechanics of inter-State production demand coordination between prison authorities, district police units and courts of different jurisdictions. Practical experience demonstrates that transit permissions, scheduling conflicts and formal compliance frequently occasion adjournments and procedural delays. Instead of expediting adjudication, repeated physical production may inadvertently generate avoidable congestion in the judicial process. IV.
III. Procedural Congestion and Inter-Jurisdictional Complexities The mechanics of inter-State production demand coordination between prison authorities, district police units and courts of different jurisdictions. Practical experience demonstrates that transit permissions, scheduling conflicts and formal compliance frequently occasion adjournments and procedural delays. Instead of expediting adjudication, repeated physical production may inadvertently generate avoidable congestion in the judicial process. IV. Exposure to Transit-Related Vulnerabilities Long-distance custodial movement inherently carries security sensitivities and operational risks. The possibility of unforeseen contingencies, including medical emergencies during prolonged transit, cannot be discounted. Escort personnel are equally exposed to risks during such movement. These vulnerabilities stand substantially minimized when judicial participation is secured through Video Conferencing within a controlled custodial environment. V. Redundancy in Repetitive Custodial Rotation Where numerous FIRs emanate from the same transaction or series of transactions, repeated custodial transfers across districts and States amount to rotational movement that does not materially advance the cause of justice. When effective judicial interaction can be ensured virtually, insistence upon repetitive physical transit appears procedurally redundant and administratively burdensome. VI. Constitutional Ethos and the Doctrine of Proportionality Article 21 of the Constitution enshrines the mandate that procedure must be fair, just and reasonable. The jurisprudence of the Video Conferencing has been considered lawful and effective mode of participation in criminal proceedings. When a less intrusive yet equally efficacious alternative exists, the constitutional principle of proportionality requires that procedural mechanisms be aligned with reasonableness rather than rigidity. VII. Harmonizing Judicial Control with Administrative Prudence Permitting appearance through Video Conferencing does not, in any manner, erode the authority or supervisory control of the concerned Court. The accused remains subject to direct judicial interaction and oversight. Simultaneously, the State’s administrative capacity is preserved, financial strain is alleviated and security risks are mitigated. A structured approach, where physical production is insisted only upon recording specific and compelling reasons would balance the majesty of the judicial process with pragmatic governance. This Court is persuaded that in cases involving multiplicity of proceedings arising from a common factual substratum, calibrated recourse to Video Conferencing would better serve the ends of justice, conserve public resources, and uphold the constitutional mandate of fairness and proportionality. 7.
This Court is persuaded that in cases involving multiplicity of proceedings arising from a common factual substratum, calibrated recourse to Video Conferencing would better serve the ends of justice, conserve public resources, and uphold the constitutional mandate of fairness and proportionality. 7. This Court may illustrate the practical implications by way of a simple example:- If an accused is lodged in judicial custody at Bikaner and is required to be produced before a Trial Court at Mandsore, M.P. pursuant to a production warrant, the jail authorities must first intimate the district police for escort arrangement. An escort team, ordinarily comprising four to six personnel depending upon security classification, is detailed for the purpose. The team travels to the jail, completes custodial documentation, and undertakes inter-district or inter- State transit which may consume an entire day or more. During this period, the escort officials remain disengaged from regular policing duties; official vehicles are exclusively deployed; daily allowances and logistical expenses are incurred; and temporary custodial arrangements are required at the destination. After production before the concerned Court, the entire process is repeated for return transit. Where multiple FIRs in different districts arise from the same set of transactions, this cycle may recur at short intervals, resulting in repetitive manpower diversion, financial expenditure and logistical strain, whereas the same judicial interaction could effectively be secured through Video Conferencing from within the controlled custodial environment, without compromising judicial authority. 8. It is not unknown to this Court that in matters where an accused is lodged in a jail situated in a different district or even another State, a production warrant often necessitates the deputation of five to seven police personnel to escort him, ostensibly to obviate any flight risk. Such personnel are required to remain stationed at bus stands, railway platforms, and transit points, braving adverse and unforeseen circumstances. The expenditure incurred towards travelling allowance, daily allowance, boarding, lodging and other incidental expenses is ultimately borne by the public exchequer. If the presence of the accused is not in dispute and identification is not a matter of contest, and the sole object is to secure a formal appearance, the question that arises is whether the mechanical issuance of production warrants, entailing the physical transportation of the accused with a sizeable escort, is justified in every case.
If the presence of the accused is not in dispute and identification is not a matter of contest, and the sole object is to secure a formal appearance, the question that arises is whether the mechanical issuance of production warrants, entailing the physical transportation of the accused with a sizeable escort, is justified in every case. When such exercise becomes a recurring monthly ritual, four times a month or every week, the cumulative financial and administrative burden is substantial. Who, then, bears the cost of deploying five to seven police officials for each such transit? Who accounts for the diversion of manpower from regular law and order duties? This Court is conscious that in cases involving numerous prosecutions, the process may assume the character of “shunting” the accused from one jurisdiction to another, with little substantive progress except formal production. In such circumstances, unless compelling reasons exist necessitating physical presence, the feasibility of securing appearance through video conferencing deserves serious consideration. The advancement of technology cannot be ignored when it offers a viable alternative that safeguards both security concerns and public resources. While there may be cases where personal production is indispensable, in matters involving limited or routine proceedings, insistence upon physical transit without due consideration of practicality may result in avoidable strain upon the exchequer and the police establishment. Judicial discretion, therefore, must be exercised not only in accordance with law, but also with a sense of administrative realism and fiscal responsibility. 9. This Court may also observe that repeated physical production across jurisdictions not only burdens administrative machinery but may inadvertently impede the expeditious conduct of trials. Frequent custodial transfers often result in adjournments owing to transit delays, overlapping production warrants and escort unavailability, thereby diluting the mandate of speedy justice under Article 21. Such movement also disrupts coordinated investigative efforts, imposes additional documentation and compliance obligations upon prison authorities, and creates practical difficulties where multiple courts list matters on the same date. Recurrent transit may curtail meaningful consultation between the accused and counsel, expose proceedings to avoidable public spectacle, and generate unnecessary logistical and environmental costs. In an era where the judicial system has consciously embraced digital integration under the e-Courts framework, regulated recourse to Video Conferencing not only preserves institutional discipline and security but also advances procedural efficiency, fairness and the dignified administration of criminal justice. 10.
In an era where the judicial system has consciously embraced digital integration under the e-Courts framework, regulated recourse to Video Conferencing not only preserves institutional discipline and security but also advances procedural efficiency, fairness and the dignified administration of criminal justice. 10. In view of the above discussion, the instant writ petition is allowed and the petitioners are permitted to attend and participate in all criminal trials pending against them through the mode of video conferencing. 11. The concerned Jail Authorities, in whose custody the petitioners are presently lodged, are hereby directed to ensure that requisite Video Conferencing (VC) facilities are made available to them as and when so required, or upon a specific requisition being made by the Court and it is expected that the said direction shall be complied with in its true letter and spirit, so that no impediment is caused in the administration of justice or in securing the presence of the petitioners before the Court through virtual mode. 12. Stay petition and all pending applications stands disposed of.