State Of Orissa vs Debendra Nath Padhi

The Supreme Court addressed whether a trial court can consider material presented by the accused at the stage of framing charges under Section 227 of the Code of Criminal Procedure, 1973. The Court reaffirmed the principle from Satish Mehra v. Delhi Administration, allowing the accused to present reliable material that could affect the sustainability of the case. However, the Court noted conflicting views from previous judgments and referred the matter to a larger bench for clarification, emphasizing the need for justice and fairness under Article 21 of the Constitution.