Exoneration in a departmental inquiry does not bar criminal prosecution for the same conduct.

The petitioners, who were accused in Crime No. 97/2015 of Malavalli Town Police Station, faced charges under Sections 406, 408, 417, 429, 465, 468 and 477A of the Indian Penal Code.

After investigation, the police filed a charge sheet alleging that the petitioners had misused their positions and acted in concert in relation to the distribution of ration to labour beneficiaries

The Magistrate took cognizance and summoned them

The petitioners sought to quash the FIR/charge sheet and the cognizance order, contending that they had been exonerated in a departmental inquiry and that the criminal case therefore violated the protection against double jeopardy

Whether exoneration in a departmental inquiry bars continuation of the criminal prosecution under Section 300 of the Code of Criminal Procedure and Article 20(3) of the Constitution, as invoked by the petitioners

Whether the FIR/charge sheet and the Magistrate’s order taking cognizance should be quashed on that basis

Section 300 of the Code of Criminal Procedure bars a second trial for the same offence, or certain offences arising from the same facts, where the accused has already been tried by a competent criminal court and convicted or acquitted

The Court held that this bar does not extend to a departmental inquiry: exoneration in such an inquiry does not, by itself, preclude a criminal prosecution

In reaching that conclusion, the Court relied on Karnataka Lokayuktha, Bagalkote District, Bagalkote v. Chandrashekar and another, 2026 SCC OnLine SC 13

The petitioners also invoked Article 20(3) of the Constitution

The petitioners’ prior exoneration occurred in a departmental inquiry, not in a trial before a competent criminal court resulting in acquittal or conviction. It therefore did not satisfy the conditions for the bar under Section 300 CrPC

The charge sheet also set out allegations and individual overt acts against the accused

Applying the Supreme Court precedent cited, the Court concluded that the departmental outcome did not justify quashing the criminal proceedings

It clarified that dismissal would not prevent the petitioners from pursuing remedies before the Trial Court, including filing a discharge application.