The Manipur High Court has set aside an NDPS conviction after finding that the Special Court failed to properly exercise the discretion vested in it under Section 229 of the Code of Criminal Procedure, 1973 while convicting the accused on her plea of guilty.

The Court observed that the conviction order was merely “one and half line”, indicating that the trial Judge had not undertaken the necessary judicial satisfaction before dispensing with a full trial.

The High Court emphasised that although a plea of guilty amounts to an admission of fact, it does not automatically warrant conviction. Before acting upon such a plea, the trial court must satisfy itself that the plea is genuine, clear and made with a complete understanding of the nature of the offence and the consequences flowing from it, particularly when the conviction is being recorded without a full-fledged trial.

Justice A.Guneshwar Sharma remarked that: “On perusal of the conviction order dated 11.03.2026, it is evident that conviction order is 'one and half line' which means that the trial Judge did not exercise the discretion conferred on it by the mandatory provisions of Section 229 of CrPC”

Background:

The petitioner, Leila @ Fajitun, was accused under Sections 21(b) and 22(b) of the NDPS Act in an FIR registered at Porompat Police Station, Imphal East. On March 11, 2026, the Special Court (ND&PS), Manipur framed charges against her, to which she pleaded guilty. The Court convicted her on the same day without conducting a full trial.

Five days later, she sought to retract her plea, stating that she had pleaded guilty under a mistaken understanding and believed that a lenient view would be taken. The Special Court rejected her application, holding that it had no power to recall the plea or the consequent conviction. She thereafter approached the Manipur High Court in revision.

The Manipur High Court held that a trial court has no jurisdiction to recall an accused's plea of guilty or review the conviction based on such plea. However, the validity of the plea and conviction can be examined by a higher court in revisional jurisdiction.

The Court observed that under Section 229 CrPC, a plea of guilty does not automatically result in conviction. The trial court must exercise judicial discretion and satisfy itself that the plea is genuine, voluntary and made with a clear understanding of the offence and its consequences.

The Court found that the petitioner's subsequent application for retraction showed that she had not fully understood the implications of her plea. The “one and half line” conviction order further demonstrated that the trial Judge had failed to exercise the required discretion.

Holding that the mandatory requirement of Section 229 was not satisfied, the High Court set aside the conviction and ordered a fresh trial.

Case Name: Mrs.Leila v/s The State of Manipur

Case No.: Crl.Rev.P. No.9 of 2026

Date of Decision: 17.08.2026

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