Court emphasizes necessity of trial for allegations concerning defamation and refuses to conduct mini-trial at preliminary stage
In a significant ruling dated January 29, 2026, the Allahabad High Court, presided over by Justice Brij Raj Singh, dismissed an application seeking the quashing of criminal proceedings against three journalists from News18 Channel. The proceedings involved allegations of defamation through a televised news segment that purportedly tarnished the reputation of an IPS officer serving as IG, STF, Uttar Pradesh.
The case, titled Jyoti Kamal v. State of U.P., revolved around a news broadcast on September 20, 2017, which suggested the officer was involved in corrupt practices. The defendants, Jyoti Kamal, Shantosh Sharma, and Gaurav Shukla, holding positions as Executive Editor, Crime Reporter, and Assistant News Editor respectively, contended that the broadcast was a fair and unbiased reportage of public interest news reported widely by other media outlets.
Despite an inquiry conducted by the Additional Director General of Police exonerating the officer of all charges, the trial court proceeded with issuing a summoning order. This was based on statements recorded under Section 200 and 202 of the Code of Criminal Procedure, 1973, leading the applicants to seek relief under Section 482 CrPC to quash the proceedings.
Justice Singh, while deliberating on the application, reiterated that the High Court could not intervene at this stage to weigh evidence or evaluate the merits of allegations, as this would amount to conducting a mini-trial. Citing precedents from the Supreme Court such as Neeharika Infrastructure v. State of Maharashtra and Sampelly Satyanarayana Rao v. Indian Renewable Energy Development Agency Ltd., the judgment underscored that the trial is essential for examining the allegations and the defense of the accused cannot be adjudicated upon during quashing petitions.
The court, referencing previous judgments and the Supreme Court's decision in Special Leave to Appeal (Crl.) No. 14790 of 2023, highlighted the principle that neither the reliability nor the genuineness of the allegations can be scrutinized at the quashing stage. The detailed inquiry report that exonerated the officer was duly considered by the Magistrate, further reinforcing the necessity of trial to resolve the disputed facts.
This decision aligns with the judicial stance that courts must refrain from delving into the merits of evidence at the preliminary stage of criminal proceedings, particularly in defamation cases where reputational harm is alleged. The ruling reiterates the balance courts must maintain between protecting individual rights and ensuring comprehensive judicial scrutiny through trial.
Bottom Line:
Quashing of criminal proceedings under Section 482 CrPC - Court cannot conduct a mini-trial or weigh evidence at this stage; allegations in the complaint and material collected during investigation must be considered as it is.
Statutory provision(s): Section 482 CrPC, Section 200 CrPC, Section 202 CrPC, Section 499 IPC
Jyoti Kamal v. State of U.P., (Allahabad)(Lucknow) : Law Finder Doc id # 2845286
