Naval Kishore Singh vs State Of Bihar

The Supreme Court held that the trial court's failure to properly examine the accused under Section 313 of the Criminal Procedure Code (Cr.P.C.) constituted a serious error, as the accused was not given adequate opportunity to explain the evidence against him. The Court emphasized that the examination under Section 313 Cr.P.C. must not be a mere formality, and the accused should be allowed to respond to each piece of evidence. Consequently, the conviction under Section 304 IPC was set aside, and the case was remanded for retrial, highlighting the importance of fair trial rights under Article 21 of the Constitution.