Section 86:
consolidated text (as at 2017). juris shows the text as it was consolidated; it does not confirm that this is the law in force today.
86. Right to Counsel—When a criminal case was called pro forma, the accused produced a letter from Counsel, suggesting dates for trial. The Magistrate refused to postpone the hearing, heard the case in the absence of
Counsel, and convicted the accused.
HELD when a case is called pro forma, there is no duty on the accused
to have Counsel or witnesses in attendance. By trying the case in the absence of Counsel, the Magistrate deprived the accused of his constitutional
rights. The conviction was quashed. Lallchand v R (1975).