Lok Ram vs Nihal Singh & Anr

The Supreme Court addressed the application of Section 319 of the Code of Criminal Procedure, 1973, emphasizing that the power to summon an accused is extraordinary and should be exercised sparingly, only when compelling reasons exist. The Court held that the High Court erred in directing the trial court to summon the appellant, Lok Ram, as the trial court had provided sufficient reasons for not exercising this power. The judgment reiterated the principles established in Michael Machado v. CBI regarding the discretionary nature of this power and the need for a judicial exercise considering the trial's stage and evidence collected.