The Supreme Court has reiterated that criminal proceedings cannot be allowed to continue when dependable material dismantles the very foundation of allegations. Emphasising that courts must intervene to prevent misuse of the criminal process, the Bench set aside proceedings against three individuals after CCTV footage contradicted claims of their involvement in an assault.
The matter stemmed from an altercation inside an apartment complex in Kolkata in October 2022. A 77-year-old resident alleged that he and his family were attacked and threatened by a group of people, leading to registration of an FIR under several provisions, including unlawful assembly, causing hurt and criminal intimidation. While the Calcutta High Court granted relief to two co-accused citing absence of specific allegations, it declined to extend the same benefit to three others, who then approached the Supreme Court.
Upon examining the material, the Court placed significant reliance on CCTV footage included in the prosecution’s own charge sheet. The footage, the Bench noted, did not depict the appellants engaging in violence. Instead, it suggested that they were attempting to calm the situation, directly contradicting the complaint.
The Court observed that when reliable and unimpeachable material effectively dislodges the factual basis of accusations and the prosecution fails to counter it, the judiciary is justified in exercising its inherent powers to quash proceedings. Allowing such cases to proceed, it added, only burdens the justice system with trials that carry no reasonable prospect of conviction.
Referring to the principles earlier laid down for assessing quashing petitions, the Court highlighted that material relied upon by the accused must be of sterling quality, capable of negating the allegations, remain unrebutted by the prosecution, and show that continuation of proceedings would amount to abuse of process. Once these conditions are satisfied, the Court said, judicial conscience should favour termination of the case at the threshold.
Applying these standards, the Bench concluded that there was no credible material connecting the appellants with the alleged offences. Continuing the prosecution in such circumstances would amount to misuse of criminal law. The appeal was therefore allowed and the pending proceedings were quashed.
