The Supreme Court has discharged a Forest Range Officer accused in a 2001 corruption case linked to alleged illegal felling and transportation of timber in Odisha, observing that the prosecution failed to specify his individual role in the alleged conspiracy.
A Bench of Justice Pankaj Mithal and Justice Prasanna B. Varale allowed the appeal filed by Susanta Kumar Dalei and set aside the Orissa High Court’s order refusing to discharge him from the case.
The case arose from an FIR registered on July 23, 2001 against Dalei and several other officials under provisions of the Prevention of Corruption Act, Indian Penal Code and Odisha Forest Act. The allegations related to large-scale illegal felling and transport of valuable timber during salvage operations in the Kalimela and Chitrakonda forest ranges of Odisha.
According to the prosecution, private firm M/s Keshari Traders, acting as a Raw Materials Procurer (RMP) appointed by OFDC, allegedly transported large quantities of timber under the guise of salvage operations, causing significant losses to the State exchequer.
A chargesheet was later filed against Dalei and other accused persons under the Prevention of Corruption Act and IPC provisions relating to forgery, conspiracy and falsification of records.
Before the Supreme Court, the appellant argued that neither the FIR nor witness statements disclosed any specific act attributable to him. It was contended that he had no role in the appointment of the Raw Materials Procurer (RMP) and that the allegations were entirely general in nature.
The State opposed the plea, maintaining that large-scale illegal felling of green trees had taken place in connivance with forest officials and private entities during the appellant’s tenure as Range Officer.
The Supreme Court found that the allegations against Dalei were broadly framed against a group of accused persons without identifying any overt act committed by him individually.
The Court observed:
“The accusations are made against a group of people together and do not explain what exactly the Appellant is supposed to have done.”
Referring to the decision in Neelu Chopra v. Bharti, the Court reiterated that criminal proceedings cannot continue merely on the basis of vague and omnibus allegations.
The Court also noted that similarly placed co-accused officers had already secured discharge earlier, and denying the same relief to the appellant would violate the principle of parity.
Allowing the appeal, the Supreme Court held that the material on record did not disclose even a “grave suspicion” against the appellant necessary to proceed to trial. The Court ruled that continuation of criminal proceedings in such circumstances would amount to abuse of the process of law.
The Court consequently discharged Dalei from the offences alleged against him and allowed the appeal.
Case: Susanta Kumar Dalei @ Susanta Kumar Dalai v. State of Odisha (Vigilance)
Case Number: Criminal Appeal arising out of SLP (Crl.) No. 9445 of 2023
Bench: Justice Pankaj Mithal and Justice Prasanna B. Varale
Date: May 18, 2026
