In a recent landmark ruling, the Supreme Court has reinforced the authority of High Courts to exercise inherent jurisdiction, even in cases where a charge sheet has been filed against the accused during the pendency of a petition seeking the quashing of an FIR. The bench comprising Justices Aniruddha Bose and Sanjay Kumar, drawing reference from the precedent set in Joseph Salvaraj A. vs. State of Gujarat & Ors., emphasized that the High Court retains the prerogative to assess whether the alleged offences are prima facie established based on the FIR, charge sheet, and other pertinent documents.
The case in question involved an appellant-accused who had filed a petition under Section 482 of the Cr.P.C. seeking the quashing of an FIR lodged against them for purported violations of Sections 420 and 409 of the Indian Penal Code. However, the High Court dismissed the petition as infructuous upon the submission of the charge sheet subsequent to the filing of the quashing plea, contending that the petition had lost relevance in light of this development.
Disagreeing with the High Court’s rationale, the Supreme Court underscored the precedent established in Joseph Salvaraj A. vs. State of Gujarat & Ors., wherein it was affirmed that even with the submission of a charge sheet, the Court possesses the authority to evaluate whether the alleged offences are prima facie established. The Court emphasized that the filing of a charge sheet does not inherently invalidate the quashing petition, necessitating a comprehensive examination of the circumstances surrounding the case.
Consequently, the Supreme Court allowed the appeal of the accused-appellant, directing the High Court to adjudicate the quashing petition on its merits. Additionally, the Court issued a stay on the arrest of the accused, pending the High Court’s decision on the petition, unless compelling circumstances arise necessitating the appellant’s detention.
In exercising its jurisdiction under Article 142 of the Constitution of India, the Supreme Court annulled the impugned order and remanded the matter to the High Court, emphasizing the imperative for a thorough consideration of the petition on its merits.
The ruling serves as a significant affirmation of the High Court’s authority to adjudicate petitions for the quashing of FIRs, even in instances where a charge sheet has been submitted during the pendency of such petitions. By upholding the principle established in Joseph Salvaraj A. vs. State of Gujarat & Ors., the Supreme Court reaffirmed the judiciary’s commitment to ensuring a fair and judicious assessment of allegations against the accused.
The decision underscores the inherent flexibility of the legal framework to adapt to evolving circumstances while safeguarding the fundamental rights of the accused. Furthermore, it highlights the judiciary’s role in upholding the principles of justice and ensuring equitable access to legal recourse.
In conclusion, the Supreme Court’s ruling represents a significant reaffirmation of the judiciary’s commitment to upholding the rule of law and ensuring fair and impartial adjudication in matters concerning the quashing of FIRs. By affirming the High Court’s authority to assess petitions on their merits, the Court has reinforced the foundational principles of justice and equity in the legal system.