Section 203 of Bharatiya Nagarik Suraksha Sanhita, 2023: Offence committed on journey or voyage

Bharatiya Nagarik Suraksha Sanhita, 2023 • Official Statutory Text & Practice Guide

Procedural Law
Statutory Mandate
Competent Criminal Court / Court of Session
Formerly Sec 183 CrPC

Legal Commentary & Landmark Judgments: Section 203

Section 203 regulates the place of trial for offences committed while the offender or victim is in the course of performing a journey or voyage, providing jurisdiction to any court through whose territory the person or conveyance passed.

  • Journey or Voyage Context: Offence committed on a train, bus, aircraft, ship, or car transit.
  • Transit Territory: Conveyance passed through multiple districts or states during the journey.
  • Omnibus Transit Jurisdiction: May be inquired into or tried by any court through or into whose local jurisdiction the person, victim, or vehicle passed in the course of that journey.
Key Landmark Precedents:
  • State of M.P. v. Suresh Kaushal (2003) 11 SCC 126: The Supreme Court held that Section 183 CrPC (Section 203 BNSS) is designed to overcome jurisdictional paralysis in transit crimes; any court along the route of the train has jurisdiction.
  • Ram Narain v. State of U.P. (1973) 2 SCC 86: Affirmed that theft or assault on commercial passenger transport can be tried at the terminating station where the journey ended.
Courtroom Practice & Strategic Litigation Guidance:

For crimes committed on long-distance trains or flights, the victim does not need to identify the exact isolated railway milepost. The FIR and trial are validly maintained at the destination railway station where the victim deboarded.