In a significant ruling, the Supreme Court on Thursday emphasised the crucial role of judicial intervention in eliminating vexatious criminal proceedings, observing that such action is necessary to shield individuals from harassment and ensure that genuine cases are not sidelined in the criminal justice system.
A bench of Justices P.S. Narasimha and Joymalya Bagchi quashed criminal prosecution against two individuals accused of assaulting a public servant in Uttar Pradesh, invoking the inherent powers of the High Court under Section 482 of the Code of Criminal Procedure (CrPC).
“Judicial intervention under Section 482 CrPC to weed out vexatious proceedings is of pivotal importance in order to protect individuals from untelling harassment and misery,” the Court stated, adding that meritless prosecutions crowd criminal courts and deprive deserving cases of due attention.
The ruling came in an appeal challenging a 2015 order of the Allahabad High Court, which had refused to quash a chargesheet filed against the appellants. The case pertained to an incident from June 2014 in Varanasi, where the appellants — including a project coordinator from an organisation working against human trafficking — had accompanied government officials to inspect a brick kiln over allegations of bonded child labour.
According to the appellants, they discovered labourers and children at the kiln and escorted them to the police station. However, the brick kiln owner allegedly intervened and took them away. Later, a police complaint was filed against the appellants, accusing them of forcibly removing the labourers.
The Supreme Court noted that the High Court had failed to examine the facts or contentions raised and merely advised the appellants to seek discharge before the trial court. “It is the duty of the High Court to ascertain whether the uncontroverted allegations in the FIR/chargesheet constitute an offence or are wholly vexatious and an abuse of the process of law,” the bench observed.
The top court also highlighted that the allegations in the chargesheet did not disclose any act of force or threatening conduct. It referred to a report submitted by the Additional Labour Commissioner of Uttar Pradesh to the National Commission for Protection of Child Rights, which accused the appellants of offering bribes — a claim the Court found “wholly unfounded” and not supported by the investigation records.
“This hostile stance of the department fortifies our conclusion that registration of the criminal case was a product of malice and personal vendetta,” the Court said, allowing the appeal and quashing the prosecution.
