PRATAP SINGH vs THE STATE OF VINDHYA PRADESH (NOW MADHYA PRADESH)

The Supreme Court examined whether Section 421 of the Code of Criminal Procedure, which allows dismissal of appeals filed by convicted persons in jail without a hearing, violates Article 14 of the Constitution. The Court held that the classification made by the legislature is rational and does not offend Article 14, as the circumstances of a convicted person in jail differ from those who can appeal in person. Furthermore, the Court ruled that a second appeal through a pleader was not maintainable due to the finality of the earlier dismissal under Section 430 of the Code.