In Manojbhai Jethabhai Parmar ( Rohit) v. State of Gujarat [2025 INSC 1433], the Supreme Court issued directions to all the trial courts aiming to institutionalize a standardized format for cataloguing witnesses, documentary evidence, and material objects. These directions intend to facilitate better comprehension and immediate reference for all stakeholders, including the Appellate Courts.
All trial Courts dealing with criminal matters shall, at the conclusion of the judgment, incorporate tabulated charts summarizing: – a. Witnesses examined, b. Documents exhibited, and c. Material objects (muddamal) produced and exhibited.
Each criminal judgment shall contain a witness chart with at least the following columns: a. Serial Number b. Name of the Witness c. Brief Description/Role of the Witness, such as: Informant, Eye-witness, Medical Jurist/Doctor, Investigating Officer (I.O.), Panch Witness, etc.
A separate chart shall be prepared for all documents exhibited during trial. This chart shall include: a. Exhibit Number; b. Description of document; c. The Witness who proved or attested the document.
Whenever material objects are produced and marked as exhibits, the trial Court shall prepare a third chart with: a. Material Object (M.O.) Number; b. Description of the Object; c. Witness who proved the Object’s Relevance (e.g., weapon, clothing, tool, article seized under panchnama, etc.)
In complex cases, such as conspiracies, economic offences or trials involving voluminous oral or documentary evidence, where the number of witnesses or documents is unusually large, the trial Court may prepare charts only for the material, relevant, and relied-upon witnesses and documents, clearly indicating that the chart is confined to such items to avoid making it an unwieldy compilation.
