SHYAMLAL MOHANLAL vs STATE OF GUJARAT

The Supreme Court held that Section 94(1) of the Code of Criminal Procedure does not apply to accused persons, affirming the High Court's interpretation. The Court reasoned that including accused persons under this section would lead to unfairness and potential self-incrimination, as the term 'person' in the statute does not explicitly encompass accused individuals. The judgment overruled the precedent set in Satya Kinkar Ray v. Nikhil Chandra Jyotishopodhaya, I.L.R. [1952] 2 Cal. 106, F.B., which had previously allowed such application.