Lack of Admissible Evidence and Independent Material Leads to Quashing of Criminal Proceedings
In a significant legal development, the Patna High Court has quashed the FIR and criminal proceedings against Sakaldeo Kumar Mandal in connection with Jamui P.S. Case No. 443 of 2023. The case, which involved serious charges under various sections of the Indian Penal Code, including forgery and conspiracy, was dismissed due to the absence of admissible evidence and independent material linking the petitioner to the alleged offences.
The court, presided over by Justice Ansul, delivered the judgment on May 15, 2026, after hearing arguments from both sides. The petitioner, represented by a team of advocates, contended that the prosecution's case was based solely on the inadmissible statement of a co-accused, Suman Kumar @ Amod Shah, and lacked any concrete evidence such as forged documents, CCTV footage, or financial transactions implicating Mandal.
The prosecution argued against the quashing of the FIR, maintaining that the charges were serious and warranted continuation of proceedings. However, the court found the prosecution's case to be built entirely on conjecture, with no substantive evidence to support the allegations. The court emphasized the importance of having admissible evidence, especially in cases involving serious charges that affect the integrity of court proceedings.
In its judgment, the court exercised its inherent powers under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to quash the FIR and related proceedings, stating that continuing the case would amount to an abuse of the judicial process. This decision underscores the judiciary's role in ensuring that criminal proceedings are not used as instruments of oppression without solid evidence.
Bottom line:-
FIR and criminal proceedings quashed due to lack of admissible evidence against the petitioner and absence of independent material connecting him to the alleged offences.
Statutory provision(s): Indian Penal Code Sections 419, 420, 466, 467, 468, 471, 120(B), 353; Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528
Sakaldeo Kumar Mandal @ Sakaldeo Mandal v. State of Bihar, (Patna) : Law Finder Doc id # 2920654
