In a significant ruling, the Supreme Court set aside criminal proceedings against three individuals accused in a neighbourhood altercation case from West Bengal. The Court found that the allegations lacked specific details and were contradicted by CCTV footage.
Background of the Case
The dispute stemmed from an incident on October 11, 2022, at a residential apartment in South 24 Parganas. The complainant alleged that several individuals formed an unlawful assembly, assaulted him and his family, and issued threats.
An FIR was registered under multiple provisions of the Indian Penal Code, including charges of assault, criminal intimidation, and outraging modesty. A chargesheet was later filed against eight accused persons.
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While the Calcutta High Court quashed proceedings against two accused, it allowed the case to continue against the present appellants, leading to the appeal before the Supreme Court.
The bench closely examined the FIR, witness statements, and crucially, the CCTV footage collected during the investigation.
The Court noted that the complaint contained general and vague allegations, without clearly specifying the role of each accused. It observed that:
“The allegations of physical assault are couched in vague terms without distinct attribution of specific overt acts.”
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On reviewing the CCTV footage, the Court found that the appellants were not present during the main altercation and appeared only later. Their conduct, the Court said, suggested an attempt to calm the situation rather than escalate it.
The bench remarked:
“At no point does the footage depict the appellants committing any overt act of assault or aggression.”
The Court also expressed concern that the High Court failed to properly consider this key electronic evidence.
Further, it pointed out inconsistency in the High Court’s approach, noting that similarly placed co-accused were granted relief while the appellants were denied it without clear reasoning.
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Referring to established principles on quashing criminal proceedings, the Court reiterated that cases can be quashed where allegations do not disclose a prima facie offence or appear malicious.
Applying these principles, the bench concluded that:
- The FIR did not establish essential ingredients of the alleged offences
- The CCTV footage contradicted the prosecution’s version
- The dispute appeared rooted in prior personal disagreements
The Court observed:
“Permitting the continuation of prosecution… would amount to an abuse of the process of law.”
Allowing the appeals, the Supreme Court quashed the criminal proceedings against the appellants, including the FIR and chargesheet, insofar as they related to them.
Case Title: Sajal Bose vs The State of West Bengal & Ors.
