The Charge

Code of Criminal Procedure - II

An attempted assignment on the topic of Charge
which would help us to know each and every
spectrum of the topic with the help of relevant
sections and the fresh precedents.
Submitted By:
Junaid Akbar Sandhu (1991FSL/LL.B(E)/F12)
Adil Nazir (1979-FSL/LL.B(E)/F12)
Uzair Ahmed (1989-FSL/LL.B(E)/F12)
Zain Khan(2020-FSL/LL.B(E)/F12)
Usman Ahmed (1998/FSL/LL.B(E)/F12)
Submitted to:
Sir Maj(R). Atta Ullah Khan Wattoo
/2015
International Islamic University, Islamabad
(IIUI).

Table of Contents
Following are the prerequisite contents which would help us in the
clarification of a topic of Charge which are herein after mention:
1. Introduction.

1.1.Charge.
1.2.Definition of Charge.
1.3.Purpose of Charge.

2. Essentials & Particulars of Charge.

3. Effect of errors and omissions in the framing of Charge.
4. Alternation in Charge and its effect on the Trial.

4.1.Court when make alterations?

4.2.Immediate trail after the alterations and further processes.
4.3.
Recalling witnesses after the alterations.

5. Joinder of Charges.

5.1.Separate charges for distinct offenses.

5.2.Series of offenses within certain time.
5.3.Trail for multiple offenses.
5.4.Persons who may be charged jointly.

6. Sample of Charge.
7. Epilogue.

Relevant Law
Section 221 to 240.
Case Laws

Nisar Ahmed Vs. The State (2015 MLD 339).

General (R) Syed Pervaiz Musharraf Vs. The State (2014 PCr.LJ
1434).
Ghulam Qadir Vs. The State (2014 PCr.LJ 865).
Iftekhar Ali Vs. The State (2013 PLD 532).

Bibliography.

Introduction
Charge

One basic requirement of a fair trial in criminal cases is to give precise information
to the accused as to the accusation against him. This is vitally important to the
accused in the preparation of his defense. In rest of the trials under the Code of
Criminal Procedure, the accused is informed of the accusation in the beginning
itself. In case of serious offenses, the Code of Criminal Procedure requires that the
accusations are to be formulated and should be taken down with great precision and
clarity. This particular Charge is then to be read and explained to the accused
person.

Definition of Charge
The Code does not give any proper definition of the charge. Basically, Charge is an
allegation on an accused person for the act and omission which he has committed
and which is made punishable under the law for the time being enforced. But
charge has been defined in the Code of Criminal Procedure, 1898 in the following
sense:
1. Literal Sense:
Literally, the charge has been defined in the following sense that,
A formal accusation of an offense as a preliminary step to prosecution 1.
2. Legal Sense:
Charge includes any head of charge when the charge contains more heads
than one. 2
So the term charge has been judicially interpreted to mean a precise formulation
of the specific accusation against a person who is entitled to know its nature at the
earliest. It denotes charge formulated after inquiry which an accused is to face in
the trial. The object of framing charge is to afford the defense an opportunity to
concentrate its attention on the case that it has to meet.

1 Blacks Law Dictionary Ninth Edition.

2 Section 4, Subsection (C), Cr.PC.
3

Purpose of Charge
Spectrum of a charge should be such that all eventualities and exigencies till the
conclusion of trail can be met with the caution so that no prejudice is caused to the
accused. Court for the purpose of a just and fair trial is duty bound to frame the
charge on the basis of the material place before it before making deeper
appreciation of such material.3 The provisions of the chapter4 in the Cr.PC relating to
charge shall give the accused full notice of the offense charged against him.

Essentials & Particulars of Charge

The sections dealing with the charge do not mention who is to frame the
charge. The provisions dealing with different types of trials however provide that it
is always for the court to frame the charge. As we will discuss later on, the court
may alter or add to any charge at any time before the judgment is pronounced. All
this has an important bearing on the administration of the criminal justice. The plea
bargaining practices prevailing in the other countries could not have any scope
here in our system, mainly because the framing of the charge and the modifications
in the charge have been mainly entrusted to the courts and not to the prosecutors.
The following are the essentials & particulars of charge.

Disclosure of Offense:
The main and the first essential of charge is that it should state the offense
with which the accused is charged and

Name of Offense:
Secondly, if the offense is named specifically by the law which creates the
offense, the offense may be described in the charge by that name only.

Relevant Law & Section:

Language of Charge:

The law and section of the law against which the offense is committed should
be mentioned.
The charge shall be written either in English or in the language of the Court.

Previous Conviction:
In case of previous conviction of the accused for affecting the sentence, the
fact, date and place of the previous conviction are to be stated and time,
place of the offense, and the person against whom of the thing in respect of
which it is committed.

Criminal Breach of Trust & Dishonest Misappropriation of

Money:

Where the accuse is charged with criminal breach of trust or dishonest

3 1993 PCr.LJ 1220.
4 Chapter XIX, Cr.PC.
4

misappropriation of money, it is sufficient to specify the gross sum in respect

of which the offense is committed and the dates between which it is
committed provided the time between the first and last date does not exceed
one year.
These are the particulars mentioned in sections 221 and 222 of the code but
when these particulars are insufficient to notify accused with the matter with
which he is charged, the charge should also contain such particulars of the
manner in which the alleged offense was committed 5.

Effect of errors and omissions in the framing of Charge

There are the couple of probabilities of mistakes in the framing of charge
and therefore, the Code has imbues the Court to make sure that any error or
omission in the framing of charge would not lead the case towards the failure of
justice. The mere omission to frame a charge or a mere defect in the charge is no
ground for setting aside a conviction. Procedural laws are designed to sub serve the
ends of justice and not to frustrate them by mere technicalities. The object of the
charge is to give an accused notice of the matter he is charged with. That does not
touch jurisdiction. If the necessary information is conveyed to him and no prejudice
is caused to him because of the charges, the accused cannot succeeded by merely
showing that the charge framed were defective 6. The combined effect of section
225 and 537 of the Code is that when any error, omission, or irregularity has
occurred in the framing of charge, the only question to consider is whether it has
occasioned a failure of justice by prejudicing the accused in his defense. This
scenario of framing of charge has been well discussed in the context of a case law
William Slaney v. State7 by the Bombay High Court in a matter 8 that a mere
defect in charge for non-framing of charge, does not vitiate the trial unless prejudice
is caused thereby to the accused, which has to be determined in each particular
case. An omission to mention particular section of Penal Code in the charge is only
an academic significance and cannot be said to have misled the accused so as to
vitiate trial9. Likewise, if there is any material error or omission then the Code has
5 Section 223 of Cr.PC.
6 Kahan Singh v. State of Haryana.
7 AIR 1956 SC 116.
8 1993 Cr.LJ 2302.
9 AIR 1956 SC 171.
5

authorized the Appellate Court or the High Court or the Court of Session power to
direct a retrial on the ground that the accused has been misled in his defense by the
absence of a charge or by an error in the charge under section 232 of the Code.

Alternation in Charge and its effect on the Trial

Charge is also subject to the alterations and the Court can do it either on its own
motion or on the application forwarded by the prosecution subject to a condition
that any addition or alteration of a charge should not prejudice the accused.

Court when make alterations?

Subject to the aforesaid condition, Charge is also subject to the alterations

and the Court can do it either on its own motion or on the application forwarded by
the prosecution subject to a condition that any addition or alteration of a charge
should not prejudice the accused10. Therefore, the Court of Sessions can alter the
charge added by him to the charge on which the commitment has been made 11. But
he cannot withdraw a charge so that the accused may be deprived of the trial by
jury and these alterations or additions should be made immediately after the charge
is explained by the magistrate. In addition, such alterations and additions can only
be made when the facts are so justified in doing it so and subject to one condition
that it should have been done prior to the pronouncement of judgment or the
verdict of the jury are returned or the opinion of the assessors is expressed as the
case may be in order to eliminate possibility of any prejudice to accused person and
should give the accused an opportunity of making such defense as the Court thinks
fit, otherwise the trial is vitiated. For this purpose, recording of some evidence

10 6 CWN 72, 31 Bom. 218: 9.

11 12 All. 551.
6

would not be needed prior to making any amendment in the charge because no
such condition is laid down under the section 227 of the Code 12.

Immediate trail after the alterations and further processes:

After the aforementioned procedure, the Court should proceed with the
trial if the charge framed or addition made to the charge is not likely to prejudice
the accused in his defense or the prosecution in the conduct of the case. The court
should treat the new or altered charge as the original charge. But where it is
doubtful whether an amendment of a charge will or will not prejudice the accused in
his defense then upon the considerable merits the further amendment ought to be
made. The addition or alteration of a charge does not open up the trial from the
beginning and the court may immediately proceed with the trial if it is of the opinion
that there will be no prejudice to the accused and if that whenever an amendment
of the charge in any way tends to prejudice the prisoner, steps should be taken to
prevent that consequence arising by ordering a new trial, or suspending the trial
going on, to enable him to make his defense, or to examine any material witness or
to recall any witnesses already examined. The same principle extends to all
instances of material prejudices arising to anyone under trial from an amendment
made in the course of the proceeding. Likewise, where a charge is altered or added
relates to an offense for the prosecution of which previous sanction is necessary,
the trial shall not proceeded with till such sanction is obtained.

Joinder of Charges
Sections 233 to 238 provide for joinder of charges in one trial of the same accused
person. Section 239 deals with joinder of charges against two or more accused in
the same trial.

Separate charges for distinct offenses:

For the sake of justice and equity, there is a general principle that each
distinct offense which has no nexus with the other offense committed at the same
time should be separately charged under the Code. Secondly, that there should be a
separate trial for every such charge. The reason behind that framing of a specific
and distinct charge regarding every distinct head of criminal liability constituting an
offense is that it is a foundation for a conviction and sentence thereof 13. The
ultimate object of the Code is to see that the accused is not bewildered in his
defense by having to meet several charges in no way connected with one another.
Therefore, the inclusion in one charge of several distinct offenses is an illegality and

12 2011 SCMR 1145.

13 AIR 1955 SC 419.
7

the conviction on such a charge must be set aside 14. For that reason under the
section 233 of the code, following are the distinct offenses:
1. Offenses falling under different sections of the same penal enactment.
2. Offenses falling under different penal enactments.
3. Offenses committed on different occasions even though they may fall under
the same section.
4. Offenses committed against different persons.
5. Misappropriations of different sums received by an accused on different dates
from different persons.
And in the following cases, the offenses of the same kind committed on one
occasion were to be taken as one offense and not distinct offense:
1. Theft of several articles from one person or more at the same time.
2. The receiving of the stolen property belonging to the different owners or
the gangs of different thefts but received at the same time.
3. The making of any number of false allegations in one statement.
4. The misappropriation of several amounts of money not proved to be
committed on different occasions.
5. A single use of forged documents as genuine in a court of law.
6. Receiving of bribe partly on one day and partly on another day.
7. Attempt to murder two persons by firing a single shoot at them.
Exceptions are available in section 234 to section 236 & 239. Unless, therefore, a
case falls within any of these four sections, it would be a breach of this section to
join a number of charges in the same trial. Such a trial is illegal as the illegality goes
to the roof of the trial.
Series of offenses within certain time:
Section 234(1), Cr.P.C. postulates that when a person is accused of more
offences than one of the same kind committed within the space of twelve
months from the first to the last of such offences accused is charged with, he
may be tried at one trial for any number of them not exceeding three.
Subsection (2) explains that offences are of the same kind when they are
punishable with the same amount of punishment under the same section of
the Penal Code or of any special or local law. An exception to this rule is an
offence under S. 379 and section 380 of the Penal Code as this is to be
deemed as an offence of the same kind. A reading of S. 234, Cr.P.C. shows
that combination of only three offences is permissible in one trial.
Nevertheless, it does not bar separate trial of the accused for rest of the
offences having been committed within a period of one year. The object of
these provisions is to avoid harassment and complication likely to occur in
evidence by joining large number of facts constituting offences of identical
nature. The principle underlying this section is that the offences of the same
14 40 Cal. 846; PLD 1950 Lah. 479.
8

kind in criminal Court within a space of short period, namely, twelve months
from the first to the last of such offences may be tried together. This section
lays down three limitations. They are,
(1) That the offences must be of the same kind.
(2) That they must have been committed within the space of one year.
(3) That more than three offences should not be joined.
Trail for multiple offenses:
In Section 235 of Code of Criminal Procedure, 1898 it is mentioned that when
the series of offenses committed by a same person within a certain time then
that person may be charger and tried together and If the offense falls within
the definition of different law for the time being in force then he will be
charge and tried for each offense and in the same way if the person is
charged with offense result of multiple actions in which one of them or couple
of them constitute itself an offense then he may also be prosecuted for such
acts. As the example is the case reported under Control of Narcotic
Substances Act (XXV of 1997) S. 9(c) Appreciation of evidence. Evidence of
recovery of narcotics from the accused was consistent on each and every
aspect of the case and the same was further supported by the Chemical,
Examiner's report disclosing the material to be opium---Contradiction pointed
out in the prosecution evidence and the improvements made therein being of
minor nature, had not changed materially the version taken in the F.I.R -Both
the accused who were going on the motorcycle having opium in their
possession had committed the offence of transporting the same in
conspiracy, abetment and association with each other. The said offence was
committed in series of the same transaction of possessing the opium and
opium could not have been transported unless the same would have been in
possession of the persons who were transporting the same as it was held that
the joint trial of the accused in the case, therefore, was not illegal- and the
conviction and sentence of accused were maintained in circumstances. As
under Section 235 & 239 the trial for more than one offence and what
persons may be charged jointly" Same transaction means Difference of
language exists between Ss.235 & 239, Cr.P.C. in which the words "same
transaction" appear and state significant difference in the language is
because under S.235. Cr.P.C. for bringing the case of joint trial, the offences
must be committed by the same person in one series of facts so connected
together as to form one and the same transaction, whereas under 5.239 (a) &
(d), Cr.P.C the requirement is that the persons who are to be tried together
should be accused of the same offence or of different offences committed in
the course of the same transaction. In order to justify a joint trial under
S.239(a) & (d), Cr.P.C. the allegation must be of the commission of different or
same offences in the course of the same transaction and possibly after
recording the evidence Court reaches a conclusion that no offences were
committed at all or that the offences were not committed in the course of the
same transaction. Such finding would not affect the legality of the trial 15.

15

PLD 2004 Karachi 508

 Persons who may be charged jointly:

Under section 239 of the Code, there are the following persons who may be
charged and their trial can be initiated together. Under the sections 233 to
238 have provided for joinder of charges against the same accused persons
in the same trial albeit the section 239 provides for joinder of charges against
more than one accused person in the same trial. The different clauses of
section 239 are not exclusive of each other. If the offenses are committed in
the course of the same transaction but the persons committing them are
covered by more than one sub-clause then they can be tried together. The
section 239 is only an enabling section and does not trammel the discretion
of the Court. The Court has discretion to proceed jointly or separately against
the accused persons. Following persons may be charged and tried together.
a. Persons accused of same offense:

Persons accused of the same offense committed in the course of

the same offense.

b. Abetment & Attempt:

Persons accused of the same offense and persons accused of abetment
or of an attempt to commit such offense.
c. Persons accused of more than one offense of same kind:
Person accused of more than one offense of the same kind within the
meaning of section 234 committed by them jointly within the period of
twelve months.
d. Persons accused of different offenses:
Persons accused of different offenses committed in the course of same
transaction.
e. Persons accused of an offense of theft, extortion or criminal
intimidation
etc:
Persons mentioned in offenses mentioned in the heading and persons
accused of receiving or retaining in the disposal or concealment of
property, possession of which is alleged to have been transferred by
any such offense committed by the first name persons or of abetment
or of attempting to commit any such last named offense.

f. Persons accused of the offense under section 411 & 414 of the
Pakistan Penal Code:
Same as above, along with the aforementioned persons or either of
those sections in respect of stolen property the possession of which he
has been transferred by one offense.
g. Persons accused of any offense relating to counterfeit of coins:
Persons accused of any offense under chapter 12 of the Pakistan Penal
Code relating to the offense of counterfeiting of coins and persons

10

accused of any other offense under the said chapter relating to coin, or
of abetment of or attempting to commit any such offense.

Sample of Charge
IN THE COURT OF SYED WAJAHAT HASAN,
ADDITIONAL SESSION JUDGE/
WITH THE POWERS OF SPL. JUDGE, CNS,
ISLAMABAD.
Special Case No. of. 2011

11

Special Trail No. of. 2011

The State
Versus
1. Yasir Khurshid son of Khurshid Khan aged about 32 years, r/o Khan Qabal Sarwana,
tehsil Hazro District Attock.
2. Waqas Qadir son of Ghulam Qadir aged about 25 years, r/o Toordhair, tehsil Chhota Lahor
District Swabi.
3. Afaq Qadir son of Ghulam Qadir aged about 27 years, r/o Toordhair, tehsil Chhota Lahor
District Swabi.
4. Yasir Farooq son of Muhammad Hussain caste Warriach aged about 24 years r/o Chani
Mast tehsil Phalia District Mandi Baha Uddin.
Accused.
Case FIR No. 297 dated 20.6.2011 U/S 9(c) CSNA police station Kohsar, Islamabad.
CHARGE.
I, Syed Wajahat Hasan, Addl. Sessions Judge/ Special Judge, CSNA, Islamabad, do hereby charge you
above named accused as under:
Those on 20.6.2011 at 1:35 A.M., in the area of NAKA D-WATSON Blue Area, Fazal Haq Road, within the
bounds of police station Kohsar, Islamabad, while you all the accused were traveling in vehicle no.
IDN/5800, on checking, you accused:
1) Yasir Khurshid was found in possession of 6 kgs;
2) Afaq Qadir were found in possession of 2 kgs of heroin,
3) Waqas Qadir were found in possession of 2 kgs, total 10 kgs, and thus you committed an offense
U/S 9(c) of CSNA, 1979, which is within cognizance of this court.
And I hereby direct that you be tried on the aforesaid charge.
Announced.

Syed
Wajahat Hasan,

04.11.2011
Judge, Spl. Court CNS, Islamabad.
Charge has been read over and explained to the accused to which they pleaded not guilty to the
charge and claimed trial. Let their statements be recorded separately.
04.11.2011
Judge, Spl. Court CNS, Islamabad.

Case Laws

12

Nisar Ahmed Vs. The State

General (R) Syed Pervaiz Musharraf Vs. The State17:

16

Nisar Ahmed and his three sons namely Shahid Ali, Yasir and Khalid were tried
for having caused fist and kicks blows to Ghulam Nabi and assaulted
complainant Mst. Zakia broke her teeth caused injuries to her mother Mai
Rani and sister Mst. Shamshad with intent to cause outrage. On 14-12-2013,
Abdul Shakoor Shaikh, Addl. Sessions Judge (Hudood), Sukkur, convicted all
the four appellants and awarded them sentence of 5 years' R.I. They were
also awarded sentence under section 354 to suffer R.I. for two years and to
pay a fine of Rs.50, 000 in default to undergo six months' R.I. Their sentences
were ordered to run concurrently. The convicts have come up in appeal.
Accused were convicted under S.324 & 354, P.P.C., despite no charge under
said section was framed. None of the alleged injured witnesses stated that
accused persons had not made murderous assault upon them, nor any sort of
question relating to that charge was put to accused persons in their
statements under S.342, Cr.P.C. So the Honorable Court held that Charge
must contain all material particulars, as to time, place as well specific name
of the alleged offences, the manner in which the offence was committed; and
the particulars of accused; so as to afford accused an opportunity to explain
the matter, with which he was charged. Purpose behind giving such
particulars, was that accused should prepare his case accordingly, and could
not be misled in preparing his defense as described under Sections 221 &
222 of the Code of Criminal Procedure.

The case as registered under Section 540-A of Penal Code (XLV of 1860) & S.
302(b) regading Qatl-e-amd. The accused has taken a plea for an exemption
from personal appearance in the court in which that accused, who had been
nominated as an accused in murder case, had sought exemption from his
personal appearance in court. Thereon, the Trial Court disposed of application
of accused vide impugned order, stating that challan (charge-sheet) had been
submitted, but the trial could not commence as accused had never (once)
appeared in court; that accused should appear in court so that the charge
could be framed, and trial could commence; that accused was at liberty to
file application for exemption at subsequent stage, or after framing of charge.
Thereon, it was held, that the impugned order of the Trial Court did not suffer
from any illegality which required correction; that in non-summons cases,
accused must be present to answer the charge; that if exemption from
personal attendance was sought, application in that respect must be
considered by the Trial Court in terms of S.540-A, Cr.P.C., but after the charge

16 2015 MLD 339.

17

2014 PCr.LJ 1434.

13

had been answered personally by accused; that State was directed to ensure
the safety of accused when he was taken to and from the court and whilst he
was present in court. So as it is described in Sections 221 & 222 charge,
framing of every charge was required to state the offence with which accused
was charged; and particulars of the offence were required to be mentioned
therein charge was to be read to accused; and if necessary, explained and
accused was asked as to how he would plead, where after his plea of
admission or denial of guilt was recorded, and if accused denied the charge,
the trial would commence. Right to respond to a serious criminal charge was
an important right of an accused, which should not be interfered with if the
attorney or lawyer was allowed to respond to a serious criminal charge, on
behalf of accused, but acted contrary to his instruction it could give rise to
difficult and complex legal and constitutional questions.

Ghulam Qadir Vs. The State18:

The Background of case is that on 19-8-2008 complainant Saleemullah Samo,
Excise Inspector, DIB Hyderabad lodged F.I.R. stating therein that he under
the supervision of Excise Inspector Jawaid Karim Mehar Incharge DIB so also
other subordinate staff acting on spy information took two mashirs namely EC
Nawaz Ali Chandio and EC Tahir Hussain under Entry No.61 at 5-00 PM,
proceeded in the official mobile from Police Station towards Tando Jam and
when they reached near Al-Medina Hotel Tando Jam, they saw the same
person at Al-Medina Hotel having black color bag in his hand who on seeing
the complainant party in uniform tried to escape away but he was encircled
and apprehended by police. On inquiry he disclosed his name as Ghulam
Qadir, then the bag which was having by the accused was opened and
checked in which 10 slabs of Charas wrapped in colored plastic were lying. On
further search Rs.500 were recovered by the complainant in presence of
witnesses. Each slab was weighed and found 1 KG each. The samples of 10
grams were separated and sealed, so also remaining property was sealed
separately. Accused also disclosed that he has purchased the said charas
from one Ali Asghar from Mirpurkhas and has brought the same here to sale
to some unknown persons. The case was recorded under Section 9(c) of
Control of Narcotics Substance Act, (XXV of 1997) thereupon Trial Court
while framing the charge and recording plea of the accused ignored the
purpose of the same. Date, time and quantity of contraband allegedly
recovered from the accused was incorrectly mentioned in the charge Said
court did not examine the material available before it and in a superficial
manner framed charge without application of mind Prosecution case was
riddled with major contradictions and illegality had been committed in
framing the charge Prosecution had failed to prove the case against the
accused and thereupon the benefit of doubt was given to the accused Appeal

18 2014 PCr.LJ 865

14

was accepted and conviction and sentence of accused was set aside. So the
Honorable Court held that Charge must contain all material particulars, as to
time, place as well specific name of the alleged offences, the manner in
which the offence was committed; and the particulars of accused; so as to
afford accused an opportunity to explain the matter, with which he was
charged. Purpose behind giving such particulars, was that accused should
prepare his case accordingly, and could not be misled in preparing his
defense as described under Sections 221, 222, 223 and 224 of the Code of
Criminal Procedure.

Iftekhar Ali Vs. The State19:

The accused were held guilty as under Section 239 Penal Code (XLV of 1860),
Sections 302/324/34/109 Qatl-e-amd, attempt to commit qatl-e-amd,
common intention, abetment. During trial case of accused was bifurcated
from case of co-accused as the former remained an absconder and nonbailable warrants were issued against him. Accused subsequently joined trial
and his case proceeded separately. Application filed by accused before Trial
Court under S.239, Cr.P.C. for consolidation of cases was dismissed. Trial
Court had rightly observed that case of accused was bifurcated from case of
co-accused to avoid delay in conclusion of trial; that evidence of 13
prosecution witnesses during trial of co-accused and 15 prosecution
witnesses during trial of accused had been recorded and all prosecution
witnesses were cross-examined at length inconvenience would be caused to
the prosecution witnesses if they were recalled and both cases were
amalgamated and accused could not point out any prejudice that would be
caused by if trials were conducted separately. Therefore, revision application
was dismissed accordingly. So it was held by the Court under Section 235 &
239 of Cr.PC that Court is not bound to try the persons or offenses jointly in
every case.

Epilogue
To conclude, it would worth mentioning that separate charges for distinct offenses
are the rule and joinder of trail is the exceptions. These exceptions are designed to
prevent the accused to be exposed to the risk of conflicting decisions and to avoid
the necessity of same witnesses giving the same evidence two or three times in
different trials and to join in one trial those offenses with regard to which the
evidence would overlap.

19 2013 PLD 532

15

Bibliography

Code of Criminal Procedure, 1898 by PLD.

Cr.Pc & Medical Jurisprudence by Naeem Anjum.
Pakistan Law Site.
Blacks Law Dictionary.
Oxford Concise Dictionary.
Wikipedia.
Scribd.

16