Lack of eye-witnesses and absence of motive render criminal proceedings an abuse of process.

The Petitioner was accused of murder following an incident on 12.05.2020 where the informant’s son allegedly went with him and was subsequently found drowned in a river

The post-mortem report concluded death was due to asphyxia and ventricular fibrillation resulting from drowning, without suggesting foul play

The police submitted a final report (finding no evidence of a crime), which the Magistrate initially accepted while converting the protest petition into a complaint. However, the Revisional Court (7th Additional Sessions Judge, Darbhanga) set aside the Magistrate’s order on 28.04.2022, directing a fresh examination, which led to the trial court taking cognizance under Sections 302 and 201 of the IPC

1. Whether the continuance of criminal proceedings against the Petitioner constitutes an abuse of the process of law in the absence of any incriminating evidence or motive

2. Whether the findings of the Revisional Court and the subsequent cognizance order were sustainable when no eyewitnesses or medical evidence supported a theory of homicide

Section 482 of the Code of Criminal Procedure (CrPC) regarding the inherent powers of the High Court to quash proceedings to prevent abuse of process

Evidentiary standards for Sections 302 (Murder) and 201 (Causing disappearance of evidence) of the Indian Penal Code (IPC), specifically focusing on the necessity of a "chain of circumstances" or direct evidence in criminal trials

The Court observed that while the Petitioner was seen in the vicinity of the river, this fact alone—consistent with the prosecution’s claim that the boy left with him—did not establish guilt for drowning or murder

Critically, the Court noted that Ashok Chaudhary, the primary source of information who allegedly saw the Petitioner fleeing, did not have these statements reflected in the initial FIR, suggesting a material omission that undermined the prosecution's case

Furthermore, the investigation failed to produce any eyewitnesses to the act or establish a motive for the alleged crime

Since the post-mortem report confirmed death by drowning without signs of "sinister" play, the Court reasoned that the evidence was insufficient to sustain a conviction, rendering the trial a futile exercise

The High Court allowed the petition and quashed the order dated 28.04.2022 passed by the 7th Additional Sessions Judge, Darbhanga. The proceedings against the Petitioner arising out of Bishanpur P.S. Case No. 37/2020 were set aside