Material inconsistencies and contradictions between ocular evidence and CCTV footage warrant quashing of summoning order.

The appellant, Mahesh Tiwari, a contractor, was accused of obstructing a government tender process at the Zila Panchayat, Mahoba, on June 28, 2025.

The complainant, Jai Prakash Anuragi (Chairman, Zila Panchayat), filed an F.I.R. on June 29, 2025, alleging that the appellant and one Ankit Shukla pushed a government employee and used loud, caste-based slurs against the complainant.

During the investigation, the complainant and witnesses provided three sets of statements under Section 161 Cr.P.C. that materially contradicted each other regarding the identity of the accused and their roles.

Despite these inconsistencies, the police filed a charge sheet based primarily on CCTV footage, and the Special Court issued a summoning order on October 14, 2025.

The appellant challenged this summoning order and the entire proceedings under Section 14-A(1) of the SC/ST Act.

1. Whether the summoning order and criminal proceedings are sustainable despite material inconsistencies and contradictions in the ocular and electronic evidence.

2. Whether the High Court has the jurisdiction to review both facts and law in an appeal under Section 14-A(1) of the SC/ST Act to quash a charge sheet/summoning order.

Section 14-A(1) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, which grants the High Court jurisdiction to review judgments or orders of a Special Court on both facts and law, notwithstanding the Code of Criminal Procedure.

State of Gujarat v. Afroz Mohammed Hasanfatta regarding the standards for taking cognizance.

While electronic evidence (CCTV) is admissible, it cannot be used to override ocular evidence that is fundamentally contradictory and lacks consistency.

Supreme Court’s directive in Sakhawat v. State of U.P. regarding the nomenclature of "Trial Courts" versus "Lower Courts".

The Court observed that the prosecution’s case was riddled with inherent inconsistencies that "go to the very root of the matter".

The complainant originally named Ankit Shukla in the F.I.R. and his first two statements, asserting he knew him well. However, in a third statement based on CCTV footage, he exonerated Shukla, claiming he was mistaken.

The Court found that the demeanor of the parties in the CCTV footage appeared "normal" and did not corroborate the allegations of a heated caste-based altercation.

The Court reasoned that the complainant’s reliance on video footage to reconstruct the event—which contradicted his own initial ocular account—cast serious doubt on the entire genesis of the case.

Since the F.I.R. was already delayed by 24 hours and the subsequent "improvements" were based on surmises and conjectures, the Court determined the proceedings were an abuse of process.

The Court set aside the impugned order dated October 14, 2025, and quashed the entire proceedings in Special Case No. 86 of 2025.

The Court directed the Registrar General to implement the Supreme Court's mandate to refer to the "court below" as the "Trial Court" and the "LCR" as the "Trial Court Record" (TCR) in all judicial and administrative records.