In a pivotal judgment, the Allahabad High Court quashed criminal proceedings against Jagdish Singh @ Jagdish Kumar Singh, a government official, noting that his exoneration in a departmental inquiry was sufficient to quash the criminal charges under the same set of facts. The case was heard under Section 482 of the Code of Criminal Procedure (CrPC), where the court deemed the continuation of criminal proceedings an unnecessary exercise.
The ruling, delivered by Justice Saurabh Lavania, was reserved on August 5, 2024, and pertains to two applications filed by Singh challenging the criminal proceedings arising from a 2020 FIR related to a COVID-19 lockdown violation.
Background of the Case
The matter dates back to May 13, 2020, when an FIR (No. 0271 of 2020) was filed at the Kakori Police Station, Lucknow, against Singh and three others under various sections of the Indian Penal Code (IPC). The complaint, lodged by Sub-Inspector Daya Shankar Singh, accused the applicants of violating lockdown rules, hurling abuses, and physically assaulting police officers during a routine lockdown enforcement operation. The charges included Sections 323, 504, 506, 307, 332, 353, 188, and 270 of the IPC, relating to causing harm to public servants, criminal intimidation, and endangering life during the COVID-19 pandemic.
After investigation, three charge sheets were filed, and Singh was implicated along with his co-accused. However, Singh, who was working as an Assistant Review Officer at the Allahabad High Court, also faced a departmental inquiry based on the same facts. The Registrar General of the High Court exonerated him from the charges in July 2021, and his suspension was subsequently revoked.
Legal Issues
The legal crux of the matter involved determining whether the criminal proceedings, based on the same facts that led to a disciplinary inquiry, should continue after the applicant had been cleared in that inquiry. The court had to decide if the exoneration in a departmental inquiry—where the standard of proof is preponderance of probability—was sufficient to quash the criminal proceedings, where the burden of proof is higher, requiring evidence beyond a reasonable doubt.
Arguments Presented
Counsel for the applicant, Abhishek Singh and Gautam Singh Yadav, contended that continuing with the criminal trial would serve no meaningful purpose since the same witnesses and evidence had been examined in the departmental inquiry, leading to Singh’s exoneration. They further argued that dragging Singh through a prolonged criminal trial would be an abuse of judicial process, as no new evidence could be introduced to significantly alter the case.
On the other hand, the state’s representative, Assistant Government Advocate S.P. Tiwari, opposed the quashing of proceedings, arguing that the departmental inquiry and criminal proceedings should be treated as separate legal matters, and the criminal case should proceed independently.
Court’s Observations and Ruling
In its ruling, the Allahabad High Court referred to the precedent set by the Supreme Court in P.S. Rajya v. State of Bihar (1996), where it was held that criminal proceedings could be quashed if the accused had already been exonerated in a departmental inquiry based on the same facts and evidence. Justice Lavania echoed this reasoning, stating, “The continuation of criminal proceedings in a situation where the applicant has been exonerated in a disciplinary inquiry on identical allegations would serve no useful purpose and would amount to an abuse of process.”
The court emphasized that while the threshold of proof in criminal trials is higher, the evidence had already been tested in the departmental inquiry, and the same witnesses were likely to be presented in the criminal trial. Given the exoneration in the inquiry, there was little chance of a different outcome in the criminal proceedings.
Allowing Singh’s applications under Section 482 CrPC, the court quashed the criminal proceedings, concluding that the exoneration in the departmental inquiry sufficed to close the case.
Case Details:
– Case Numbers: Application U/S 482 No. 5413 of 2024 (connected with Application U/S 482 No. 2283 of 2023)
– Bench: Justice Saurabh Lavania
– Applicants: Jagdish Singh @ Jagdish Kumar Singh
– Opposite Party: The State of U.P. through Principal Secretary Home, Lucknow
– Counsel for Applicant: Abhishek Singh, Gautam Singh Yadav, Akhand Kumar Pandey
– Counsel for Opposite Party: S.P. Tiwari (Assistant Government Advocate)
