Supreme Court finds the High Court erred in not considering vital CCTV evidence exonerating appellants in assault case.
In a significant judgment delivered on April 6, 2026, the Supreme Court of India quashed the criminal proceedings against Sajal Bose and two others, emphasizing the misuse of the legal process and the failure of the High Court to consider critical evidence. The apex court's decision came in response to an appeal against the Calcutta High Court's judgment that had denied relief to Bose and his co-appellants, despite quashing proceedings against other similarly charged individuals.
The case arose from an incident on October 11, 2022, involving an altercation at an apartment complex in Kolkata. The complainant, Sushil Chakrabarti, had alleged that the appellants, along with others, engaged in physical assaults and issued threats. However, the Supreme Court found that the allegations in the FIR did not prima facie establish any offense by the appellants, noting the absence of specific acts attributed to them.
Central to the Supreme Court's ruling was the CCTV footage, which the court found to be of "unimpeachable quality" and clearly demonstrating that the appellants were not involved in the alleged acts of assault. The footage, which the High Court failed to adequately consider, showed the appellants arriving after the incident had escalated and attempting to mediate rather than incite further conflict.
The judgment criticized the High Court's arbitrary approach in granting relief to some accused while denying it to others without cogent reasons. The Supreme Court reiterated the principles established in landmark cases like State of Haryana v. Bhajan Lal, emphasizing that proceedings should be quashed when they are instituted with malafide intent or when no prima facie case is made.
This ruling underscores the judiciary's role in preventing the abuse of legal processes and ensuring that justice is not only done but seen to be done. The court's decision highlights the importance of evaluating all evidence, particularly electronic evidence, before proceeding with criminal trials.
Bottom Line:
Quashing of criminal proceedings under Section 482 CrPC (Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023) is justified when allegations and evidence do not prima facie establish offences and continuation of the case would amount to abuse of process of law.
Statutory provision(s): Section 482 of the Criminal Procedure Code, 1973 (Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023), Sections 143, 341, 323, 324, 504, 506, 509, 427, and 354 of the Indian Penal Code, 1860.
Sajal Bose v. State of West Bengal, (SC) : Law Finder Doc id # 2878664
