Can Criminal Proceedings Be Quashed After Filing of Charge Sheet? Supreme Court Clarifies

The Supreme Court reiterated that criminal proceedings can be quashed even after a charge sheet is filed, emphasizing that there is no legal prohibition against such an action.

A bench comprising Justices PS Narasimha and Pankaj Mithal quashed a domestic cruelty case against the accused, observing that no new allegations emerged from the charge sheet, and the accusations remained identical to those in the First Information Report (FIR).

Legal Precedents and Court Observations

The Court referred to established precedents affirming that High Courts have the inherent power under Section 482 of the Criminal Procedure Code (CrPC) to quash criminal cases at any stage, including after the charge sheet is filed. This inherent power is often invoked to prevent the abuse of legal process or miscarriage of justice.

“There is no prohibition against quashing criminal proceedings even after the charge sheet has been filed,” the bench observed, reiterating the legal stance on this issue.

In the case of Mama Shailesh Chandra v. State of Uttarakhand, the Court opined that even if a charge sheet is filed, the court can still assess whether the alleged offenses are prima facie established based on the FIR, charge sheet, and other documents. Similarly, in the case of Anand Kumar Mohatta vs. State (NCT of Delhi), it was held that criminal proceedings can be interfered with by the High Court to prevent abuse of process even after the charge sheet is filed if the allegations do not constitute an offense.

Scope of High Court's Powers under Section 482 CrPC

The Court highlighted that Section 482 CrPC does not restrict the High Court's powers to intervene only at the FIR stage. The powers extend to any stage of the criminal process, including when a charge sheet has been filed. The Court noted that holding otherwise would be illogical, as the abuse of process could be considered more aggravated once an FIR progresses to a charge sheet.

“It is a well-established principle of law that the High Court can exercise its jurisdiction under Section 482 CrPC even when a discharge application is pending with the trial court. Preventing intervention at the charge sheet stage would be a travesty, as it would mean that while abuse of process can be addressed at the FIR stage, it cannot be remedied once formal charges are brought,” the Court observed in the Anand Kumar Mohatta case.

This ruling reinforces the judiciary's commitment to safeguarding individual rights against baseless or malicious prosecutions, ensuring that the criminal justice system remains fair and just at every stage.