Recently, the Supreme Court drew a sharp line on when criminal trials must come to a halt, holding that proceedings cannot be allowed to continue when credible and unimpeachable material dismantles the very foundation of the accusations. Intervening in a case where the High Court had declined relief, the Court stepped in to clear the Appellants of criminal prosecution, making it clear that forcing an accused to face trial despite exculpatory evidence would turn the process itself into an instrument of injustice.
Brief Facts:
The case arose from an FIR alleging offences under multiple provisions of the Indian Penal Code, including Sections 143, 341, 323, 324, 504, 506, 509, 427, and 354, stemming from a dispute within a residential complex involving allegations of assault, intimidation, and unlawful assembly. Following the investigation, a charge sheet was filed, and proceedings were initiated before the Magistrate. The accused invoked the High Court’s jurisdiction under Section 482 of the CrPC (now Section 528 of the BNSS) seeking quashing of the case; however, while relief was granted to some co-accused, it was denied to the present appellants, leading them to approach the Apex Court.
Contentions of the Appellant:
The Appellants argued that the criminal proceedings were maliciously instituted due to prior disputes and lacked specific allegations attributing any overt act to them. The Counsel contended that the FIR contained vague and omnibus allegations, insufficient to constitute the offences alleged. Crucially, reliance was placed on CCTV footage forming part of the charge sheet, which demonstrated that the appellants were not involved in the alleged assault and had only intervened to pacify the situation. The Appellant further argued that the High Court failed to consider this crucial electronic evidence and also erred in denying parity with co-accused who had been granted relief.
Contentions of the Respondent:
The Respondent opposed the plea, asserting that the Appellants actively participated in the assault and intimidation, supported by witness statements under Sections 161 and 164 of the CrPC and medical evidence indicating injuries. The Counsel argued that the CCTV footage corroborated the prosecution's case and that the allegations disclosed a clear prima facie case warranting trial. The State also supported the continuation of proceedings, contending that disputed factual issues should be adjudicated during trial and not at the stage of quashing.
Observation of the Court:
The Division Bench of Bench Justice Vikram Nath, Justice Sandeep Mehta, and Justice N. V. Anjaria observed that “Where reliable and unimpeachable material demonstrably displaces the factual basis of the accusations and the prosecution is unable to effectively counter the same, the Court would be justified in invoking its inherent jurisdiction to prevent injustice. Such an approach not only accords justice to the accused but also obviates the wastage of precious judicial time on proceedings which, on the admitted material, do not hold a reasonable prospect of culminating in conviction.”
The Court observed that the inherent jurisdiction to quash criminal proceedings is meant to prevent abuse of the process of law and to secure the ends of justice. It emphasised that such power must be exercised where the allegations, even if taken at face value, fail to disclose the commission of any offence. The Bench reiterated that the principles laid down in State of Haryana v. Bhajan Lal continue to guide such exercise, particularly in cases involving vague allegations or mala fide prosecution. It further clarified that courts must not hesitate to intervene at the threshold when the continuation of proceedings would serve no legitimate purpose.
The Bench held that material forming part of the prosecution record, especially electronic evidence such as CCTV footage, must be given due weight even at the stage of quashing. It observed that such evidence, if of sterling and unimpeachable quality, can decisively undermine the prosecution’s case. The Bench emphasised that ignoring such material would amount to a failure in judicial scrutiny, particularly when the same directly addresses the core allegations. It further noted that the High Court erred in not independently analysing the CCTV footage, which had a direct bearing on the culpability of the accused.
The Court observed that the FIR and subsequent material were replete with general and omnibus allegations, without clearly attributing specific overt acts to the appellants. It emphasised that criminal liability cannot be fastened in the absence of clear and distinct roles, especially in cases involving multiple accused. The Bench noted that mere presence or subsequent arrival at the scene does not satisfy the ingredients of serious offences alleged under the IPC. It further held that such vague allegations, when read with contrary evidence, cannot justify subjecting individuals to a criminal trial.
The Bench held that the High Court’s approach in granting relief to some co-accused while denying the same to the appellants, despite similar allegations, was unsustainable. It observed that such differential treatment, without cogent reasoning, violates the principle of parity and undermines judicial consistency. The Bench emphasised that when allegations arise from the same incident and are materially identical, courts must adopt a uniform approach unless distinguishable facts are clearly demonstrated. It concluded that the absence of such reasoning rendered the High Court’s decision flawed.
The Court observed that compelling the appellants to undergo a full-fledged criminal trial, despite the absence of credible material linking them to the alleged offences, would amount to misuse of the criminal process. It emphasised that the purpose of criminal law is not to harass individuals through prolonged litigation where conviction is improbable. The Bench highlighted that continuation of such proceedings would waste judicial time and defeat the ends of justice. It therefore held that intervention at the initial stage was necessary to prevent injustice and uphold fairness.
The decision of the Court:
In light of the foregoing discussion, the Apex Court allowed the appeals, set aside the High Court’s order, and quashed the criminal proceedings against the Appellants. It held that when credible and unimpeachable evidence, such as CCTV footage, clearly negates the allegations and remains unchallenged, continuation of criminal prosecution would constitute an abuse of process.
Case Title: Sajal Bose Vs. The State of West Bengal and Ors.
Case No.: SLP (Crl.) No. 8672 of 2024
Coram: Hon’ble Mr. Justice Vikram Nath, Hon’ble Mr. Justice Sandeep Mehta, Hon’ble Mr. Justice N. V. Anjaria
Advocate for the Petitioner: Sr. Adv. Gaurav Agarwal, AOR Advinmayee Sahu, AOR Khaitan, Adv. Diwakar Maheshwari, Adv. Karun Mehta, Adv. Shounak Mitra, Adv. Pratiksha Mishra, Adv. Shreyash Edupuganti, Adv. Kaarunya Lakshmi,
Advocate for the Respondent: Sr. Adv. Siddhart Luthra, AOR Kunal Chatterji, AOR Anwesha Saha, AOR Vanshaja Shukla, AOR Kunal Mimani, AOR Vipin Nair, Adv. Maitrayee Banerjee, Adv. Rohit Bansal, Adv. Varij Nayan Mishra, Adv. Shraddha Chirania, Adv. Siddhant Yadav, Adv. Salim Ansari, Adv. Nitish Shani, Adv. Ramya MB, Adv. Karl P. Rustom Khan, Adv. Suhail Ahmed, Adv. Parv Arora
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