A co-accused’s police statement alone cannot implicate another accused absent supporting material.

The applicant, a director of Singhal Plywood Industries Private Limited, sought quashing under Section 482 CrPC of an FIR registered at Bhachau Police Station for offences under Sections 406, 409, 381, 34 and 120-B IPC and Sections 3 and 7 of the Essential Commodities Act, 1955.

The FIR alleged that agricultural urea intended for farmers was being diverted to the applicant’s plywood factory.

The applicant contended that the allegation rested solely on a co-accused’s police statement, that no urea was recovered from his premises, and that there was no other material connecting him to the alleged diversion.

The State accepted that it could point to no material implicating the applicant apart from that statement.

The Court reviewed the FIR and investigation papers.

1. Whether the FIR disclosed material, apart from a co-accused’s police statement, connecting the applicant to the alleged diversion of urea.

2. Whether the FIR should be quashed qua the applicant under Section 482 CrPC where the alleged connection rested solely on that statement.

Section 482 CrPC empowers the High Court to quash criminal proceedings in an appropriate case.

The Court relied on P. Krishna Mohan Reddy v. State of Andhra Pradesh, 2025 SCC OnLine SC 1157, for the principles governing police statements of accused persons under Sections 161–162 CrPC and the admissibility of confessions under Sections 24–30 of the Evidence Act.

In particular, a police statement of an accused that implicates a co-accused cannot, by itself, be used as substantive evidence against that co-accused; Section 30 permits consideration of a co-accused’s confession only at trial when its statutory conditions are met, and then only as a rule of prudence alongside other evidence.

The Court found that the investigation papers disclosed no material implicating the applicant beyond the co-accused’s statement; the State also identified no independent supporting material.

Applying P. Krishna Mohan Reddy, the Court held that an accused’s police statement implicating another accused could not supply the missing evidentiary foundation.

It also noted the absence of call-detail records linking the applicant to the co-accused.

On that record, the allegation against the applicant could not be sustained.

It quashed and set aside the FIR, C.R. No. 11993004200862 of 2020, qua the applicant; the Rule was made absolute to that extent, with direct service permitted.