Criminal case quashed after police SIT found eight cases against family fabricated; officer’s complicity recorded

The petitioners challenged the criminal proceedings arising from FIR/Crime No. 14/2021 registered at Police Station Jarhagaon, District Mungeli, for offences under Sections 420, 120-B and 212 of the Indian Penal Code, including Chargesheet No. 61/2021, Supplementary Chargesheet No. 129/2022 and the order framing charges.

The prosecution arose against the background of a personal dispute between Petitioner No. 2 and Respondent No. 10, Piyush Tiwari, who had allegedly been in a relationship with her and subsequently initiated criminal proceedings after she ended the relationship and married Petitioner No. 1.

The petitioners contended that the impugned FIR formed part of a series of eight criminal cases lodged against substantially the same family members, allegedly through the influence of Respondent No. 3, a senior police officer associated with Respondent No. 10.

A subsequent Special Investigation Team inquiry allegedly found the eight cases to be fabricated, recorded the complicity of Respondent No. 3, and led to recommendations for disciplinary proceedings against him; negligence was also found in the investigation of one connected case.

Several connected proceedings had resulted in closure reports or had been stayed.

Respondent No. 10 denied mala fides and argued that the individual FIR had to be assessed on its own allegations and evidence, and that the SIT report and developments in other cases could not substitute for a criminal trial.

Whether the High Court should exercise its inherent jurisdiction under Section 482 CrPC to quash the FIR, chargesheets, order framing charges and consequential proceedings arising from Crime No. 14/2021?

Whether the cumulative circumstances—including the series of proceedings, repeated implication of the petitioners’ family, the SIT findings, closure reports, and disciplinary action against police officials—established that continuation of the prosecution would constitute mala fide abuse of process?

Whether the filing of the chargesheet and framing of charges barred interference under Section 482 CrPC?

The Court applied Section 482 of the Code of Criminal Procedure, which preserves the High Court’s inherent power to prevent abuse of the process of any court and to secure the ends of justice.

Although the power is extraordinary and must be exercised sparingly, the filing of a chargesheet or framing of charges does not create an absolute bar where continuation of the prosecution would result in manifest injustice or abuse of process.

The Court relied principally on State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335, particularly the category permitting quashing where criminal proceedings are manifestly attended with mala fide or maliciously instituted with an ulterior motive to wreak vengeance arising from a private or personal dispute.

The Court also recognised that, at the Section 482 stage, it should not conduct a mini-trial or undertake detailed appreciation of disputed evidence.

The Court held that no individual circumstance—such as the existence of multiple FIRs, common accused, connected complainants, police postings, closure reports or the SIT report—was conclusive by itself.

However, their cumulative effect was significant.

The impugned FIR formed part of a sequence involving substantially the same family members, and the cases were registered in jurisdictions where Respondent No. 3 held relevant police positions.

More importantly, the allegation of police misuse was supported by subsequent official material placed on record by the State itself: the SIT reportedly found the eight offences fabricated, recorded Respondent No. 3’s complicity, found negligence in a connected investigation, and led to disciplinary proceedings or recommendations against the concerned police officials.

The Court did not treat the SIT report as a conclusive adjudication or determine the merits of the other proceedings; it considered the report as relevant official material demonstrating that the prosecution’s initiation and continuation required scrutiny.

In these peculiar circumstances, requiring the petitioners to undergo trial would perpetuate a continuing course of criminal harassment and amount to abuse of process falling within the Bhajan Lal principles.

The petition was allowed, and Crime No. 14/2021, Chargesheet No. 61/2021, Supplementary Chargesheet No. 129/2022, the order framing charges passed by the Judicial Magistrate First Class, Mungeli, and all consequential criminal proceedings were quashed/set aside.

The petitioners were left at liberty to pursue their other reliefs before the appropriate forum.