STATE OF MADHYA PRADESH vs SHOBHARAM AND ORS.

The Supreme Court held that Section 63 of the Madhya Bharat Panchayat Act, 1949, which prohibits legal practitioners from appearing before the Nyaya Panchayat, violates Article 22(1) of the Constitution, as it denies the right to legal representation. However, the Court found that the High Court erred in quashing the conviction since the respondents did not claim the right to counsel during their trial, and thus, the violation did not cause them prejudice. The Court clarified that the constitutional right to counsel applies only in cases where personal liberty is at risk, which was not the case here as the penalty was limited to a fine.