IPC Section 20 - “Court Of Justice”

In criminal law, understanding who has the authority to conduct legal proceedings and deliver judgments is critical. This is where the concept of a “Court of Justice” under the Indian Penal Code (IPC) becomes significant. IPC Section 20 defines this term, laying the foundation for interpreting various offences like perjury, obstruction of justice, or assault on judicial officers.

This blog will help you understand:

• The legal definition of “Court of Justice” under IPC
• Who qualifies as a court under this definition
• Real-life implications and legal relevance
• Examples to illustrate its application
• Relevant case laws and frequently asked questions

Legal Definition Of “Court Of Justice” – IPC Section 20

Bare Act Text:

“The words “Court of Justice” denote a Judge who is empowered by law to act judicially alone, or a body of Judges which is empowered by law to act judicially as a body, when such Judge or body of Judges is acting judicially.

Simplified Explanation:

On one hand, a court of justice would be any individual or group of individuals with power of law to render judicial decisions provided they are functioning in a judicial capacity. This very definition drives the applicability of certain criminal offences to matters pertaining particularly to the giving of false evidence, contempt, or any offence done in the course of judicial proceedings.

Who Qualifies As A “Court Of Justice” Under IPC?

According to Section 20 of IPC, "Court of Justice" means:

1. An Individual Judge

For example, a Magistrate or Sessions Judge sitting in a criminal trial, acting judicially, is a Court of Justice.

2. A Bench or a Panel of Judges

On the occasion when a group of judges, such as one Bank of High Court, hears and decides a matter, these judges will act together as a Court of Justice.

3. Only While Acting Judicially

This is an important point. The judge or judges must have been performing a judicial function, namely hearing a case, considering evidence, making decisions, or applying the law. They are not a Court of Justice when acting in an administrative or non-judicial capacity.

Practical Importance Of IPC Section 20

The definition that judges or judicial bodies acting as "Court of Justice" extends:

1. Application of Other Sections of IPC

Certain sections are similar in content with provisions of IPC, such as:

• Section 193- Giving false evidence in the Court.
• Section 228- Intentional insult to public servant in judicial proceeding; i.e., when these sections are to be applied, the Court of Justice, as defined under IPC Section 20 , must be invoked because only when the act is carried out before a Court of Justice, does it become an offence.

2. Protection and Implied Immunity to a Judicial Functionary

In short, the profuse immunities laid down by the IPC, the Code of Criminal Procedure (CrPC), etc. are often conferred upon those who act as "Courts of Justice". An action taken under this context enjoys immunity until proven otherwise to have been done with mala fides or out of jurisdiction.

Examples Illustrating IPC Section 20

Example 1:

A Civil Judge sounds the dispute in a land case, records the witness statement, and hands down a judgment. In all these acts, a voice is issued by the Court of Justice. Any witness may have made false statements that could attract charges under Section 193 IPC for giving false evidence before a Court of Justice.

Example 2:

In the theft case, a Metropolitan Magistrate issues a non-bailable warrant. If any attempt is made to bribe or insult him, it will constitute an offence against the "Court of Justice" in the sense of Perjury.

Example 3:

If the same judge is observed later directing staff as to how to organize court files, this administrative function does not fall within the definition of "Court of Justice."

Legal Significance Of Defining “Court Of Justice”

The definition of "Court of Justice" assists in the following:

• Determining Jurisdiction: To ensure the case is put through only those judicial authority which has the jurisdiction to do so.
• Framing of Charges: To explain matters of perjury, for example, as to whether the falsehood was uttered in a judicial setting.
• Upholding the Dignity of the Court: The law acknowledges the dignity of judicial processes and protects such dignity.
• Curtailing Abuse: It narrows the application of these protections to judicial functions, not administrative ones.

Landmark Case Law On 'Court Of Justice'

To better understand the scope and interpretation of “Court of Justice” under IPC Section 20, here are some landmark judgments that clarify how Indian courts have defined and applied this provision in real-world legal contexts.

1. Queen Empress v. Tulja (1887)

Court: High Court of Bombay

issue: To decide whether an act performed by a person in a judicial character amounts to a "Court of Justice" under Section 20 of the IPC.

Held: In Queen Empress v. Tulja (1887) court held that an entity must be empowered by law to assume a judicial function to qualify as a "Court of Justice." Administrative functions or others that are non-judicial, in their mere performance, cannot suffice.

2. Brajnandan Sinha vs. Jyoti Narain

Court: Supreme Court of India

issue: Whether a Commission of Inquiry could be included in the meaning of "Court of Justice" as described under Section 20 of the IPC.

Held: In Brajnandan Sinha vs. Jyoti Narain Supreme Court held that a Commission of Inquiry could not qualify to be considered as a "Court of Justice" in view of the fact that it did not have the power to give binding adjudications.

3. Shri Balwan Singh v. Shri Lakshmi Narain & Others

Court: Supreme Court of India

issue: Interpretation of judicial authority and its contours on the subject of election petitions.

Held: In Shri Balwan Singh v. Shri Lakshmi Narain & Others Supreme Court discussed the need for particulars in election petitions and the implications for judicial bodies dealing with such matters.

Conclusion

Moreover, within the framework of IPC Section 20 can be found the very groundwork upon which stands the definition of what is a Court of Justice in India. This definition further governs the manner in which prosecution for the other grave offenses, such as giving false evidence or insult to a judge or contempt, would proceed. The line drew so fine would be as well-narrowed that only persons acting judicially under lawful authority shall be recognized as a Court of Justice.

One must have a grip over this section in order to understand any legal process-whether as a litigant, witness, proxy, lawyer, or any other public servant. As such, it would ensure that all the roles in the judiciary are respected, protected, and defined.

Frequently Asked Questions (FAQs)

Still have questions about IPC Section 20? Here are some frequently asked questions to help clarify key concepts, practical implications, and common doubts related to the definition of “Court of Justice.”

Q1. What is meant by "Court of Justice" under IPC Section 20?

Those judges or groups of judges empowered to act judicially, such as hearing evidence, passing judgments, and resolving disputes.

Q2. Does this involve every officer of the government?

No. Only those who act judicially and are empowered by law to legally enact decisions are included. Other administrative officers or quasi-judicial authorities not acting as judges are excluded.

Q3. What is the difference between a "Judge" and a "Court of Justice"?

A judge is an individual endowed with judicial powers (defined in IPC Section 20). A Court of Justice is a judge (or judges) acting judicially, collectively recognized as a legal body conducting trials or proceedings.

Q4. Is a tribunal considered a Court of Justice?

Only if the tribunal or its members are authorized under law to act judicially and their actions are judicial in nature (e.g., adjudicating disputes, generating enforceable rulings).