The Supreme Court on March 26 overturned the Madras High Court’s decision to quash a disproportionate assets case against a bureaucrat at the pre-trial stage. The High Court had dismissed the case citing "bleak conviction prospects" and "invalid sanction" for prosecution. However, the Supreme Court held that such determinations should be made during the trial and not at the pre-trial stage.

The bench, comprising Justices PS Narasimha and Manoj Misra, ruled that the High Court had overstepped its jurisdiction by conducting what amounted to a mini-trial before the actual evidence was presented. The Court emphasized that issues concerning the validity of sanction and conviction prospects should be determined only during the trial.

"We are of the clear opinion that the High Court has exceeded the well-established principles for exercising jurisdiction under Section 482 of the Cr.P.C.," the Supreme Court observed.

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The Court further clarified:

"This is typically the problem that would arise when the High Court seeks to interdict proceedings and quash the criminal case before the relevant material to support the prosecution is brought on record. Findings regarding the legality, validity, or delay in the grant of sanction were premature. Validity of the sanction is an issue that must be examined during the course of the trial."

Case Background: Disproportionate Assets Allegation Against Bureaucrat

The case involved allegations that the accused, a public servant, had acquired assets worth Rs. 26,88,057/- disproportionate to his known sources of income between 2001 and 2008. Consequently, an FIR was registered against him under Sections 13(2) read with 13(1)(e) of the Prevention of Corruption Act, 1988.

The accused initially sought discharge from the trial court, which was rejected on the grounds that a prima facie case existed against him. A subsequent revision petition filed before the High Court was also dismissed, upholding the trial court’s decision. However, the accused then approached the High Court with a quashing petition under Section 482 CrPC, which resulted in the FIR being quashed.

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The Supreme Court strongly criticized the High Court for overstepping its authority by delving into factual disputes at the pre-trial stage. The Court noted that questions regarding the accused's wife’s real estate income, alleged gifts from the accused’s daughter, and the validity of sanction were factual matters that needed to be examined during the trial.

"Instead of determining whether there is sufficient ground for proceeding against the accused based on the material, the High Court asked the wrong question—whether that would warrant a conviction," the Court stated.

The ruling referenced the precedent set in State of T.N. v. N. Suresh Rajan, (2014) 11 SCC 709, where the Supreme Court held that courts should not evaluate evidence at the pre-trial stage as if deciding an acquittal.

Applying this principle, the Court concluded:

1. The High Court erred in quashing the prosecution based on the alleged illegality of sanction.
2. The objections raised in the quashing petition were identical to those in the revision petition, which had already been dismissed.
3. No material change in facts justified the High Court’s decision to quash the case.
4. The validity of sanction can always be examined during trial.
5. A mere delay in granting sanction does not warrant quashing a criminal case.

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"There is no doubt that the High Court committed an error in quashing the prosecution on the ground that the sanction to prosecute is illegal and invalid," the Supreme Court held.

With this ruling, the Supreme Court allowed the State’s appeal and directed that the trial be resumed without further delay. The Court also ordered an expedited hearing, considering that the case had already been delayed for 17 years.

Case Title: STATE Vs. G. EASWARAN

Appearances:

For Appellant(s) : Mr. Sabarish Subramanian, AOR Mr. Poornachandiran R, Adv. Mr. Vishnu Unnikrishnan, Adv. Mr. Danish Saifi, Adv.

For Respondent(s) :Mr. Dama Seshadri Naidu, Sr. Adv. Mr. Abhishek Gupta, AOR Mr. Praful Shukla, Adv. Mr. Nikhil Kumar Singh, Sr. Adv.