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In which Supreme Court of India decision did the Court uphold the validity of section 172(3) of the…

Mukund Lal v Union of India upheld section 172(3). The accused could neither call for the diary nor see it merely because the court referred to it. The provision made…

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In which Supreme Court of India decision did the Court uphold the validity of section 172(3) of the former Code of Criminal Procedure, 1973, concerning the accused’s access to the police case diary?

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Correct answer C

Mukund Lal v Union of India upheld section 172(3). The accused could neither call for the diary nor see it merely because the court referred to it.

The provision made limited evidentiary safeguards available when the officer used the diary to refresh memory or the court used it to contradict that officer.

Option feedback

Option A

Harish Chandra Singh concerned a police officer’s removal from service.

Option B

In re Madhu Limaye concerned constitutional safeguards following arrest and detention.

Option C

Mukund Lal upheld section 172(3), taking account of the court’s access to the diary and the statutory safeguards for the accused.

Option D

Khatri (II) concerned legal aid and protections for indigent accused persons.

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