In a rather tense hearing at the Supreme Court on Friday, the bench led by Justice Sanjay Karol overturned the prosecution launched against IAS officer Robert Lalchungnunga Chongthu, accused of irregularly issuing arms licences back in 2004. The Court expressed discomfort at how a 20-year-old matter had been dragged on “without any meaningful progress,” calling the sanction order against the officer mechanically issued and legally unsustainable.
The dispute stemmed from allegations that Chongthu, then District Magistrate of Saharsa, issued licences without adequate police verification. But the Court wasn’t quite convinced that the State had done its homework before prosecuting him.
Background
The controversy goes back to 2002–2005, when the appellant served as DM-cum-Licensing Authority in Saharsa, Bihar. An FIR was filed in 2005 alleging that several licences were granted to unverified or untraceable individuals. Investigation led to a supplementary chargesheet in 2006, expressly stating that allegations against the officer were “false”. Despite this, further investigation was ordered years later.
Shockingly, the final chargesheet naming the IAS officer surfaced only in 2020, a full 15 years after the FIR, and sanction for prosecution came in 2022. The trial itself had not moved an inch even by 2024.
Court’s Observations
The bench repeatedly questioned why the State slept on the investigation for more than a decade. At one point, the bench observed, “How long can a citizen remain under a cloud of criminal proceedings, especially when the case itself stood dormant for years?”
The Court also found severe flaws in the sanction order under Section 197 CrPC. Calling it vague and mechanical, Justice Karol noted:
“The sanction merely says ‘on perusal of documents’ without explaining what was considered or how the authority applied its mind.”
The Court referenced earlier judgments emphasising that sanction is not just a clerical formality but a “sacrosanct safeguard” protecting public officials from frivolous prosecution.
Another line of concern was the inordinate delay. The judgment highlighted that right to a speedy trial begins from the investigation stage itself. The Court reminded the State that delays spanning a decade or more can choke an accused’s ability to defend themselves and violate Article 21.
The bench remarked, “We cannot allow proceedings to continue endlessly. There must be an end somewhere, and fairness demands it.”
Decision
After examining the record, the Supreme Court set aside the sanction, declared it legally invalid, and consequently quashed the cognizance and all further proceedings against the IAS officer. The judgment ends firmly, clarifying that prosecution cannot continue when the very foundation-sanction-is void.
Case Title: Robert Lalchungnunga Chongthu @ R. L. Chongthu vs. State of Bihar
Case Number: Criminal Appeal (Arising out of SLP (Crl.) No. 10130 of 2025)
Case Type: Criminal Appeal – Challenge to refusal to quash cognizance under Section 482 CrPC
Court: Supreme Court of India, Criminal Appellate Jurisdiction
Bench: Justice Sanjay Karol (author of the judgment)
Decision Date: 2025