The Supreme Court has brought an end to criminal proceedings against former Prime Minister Dr. Manmohan Singh in the Talabira-II coal block allocation case, holding that there was no valid reason for the trial court to reject the Central Bureau of Investigation's (CBI) closure reports. The Court allowed Dr. Singh's appeal, set aside the orders summoning him, and formally accepted the CBI's findings.
Background of the Case
The case arose from the allocation of the Talabira-II coal block in Odisha during the UPA government's tenure, when Dr. Manmohan Singh was also handling the coal portfolio. After investigating the matter, the CBI filed two closure reports in 2014, concluding that no prosecutable case was made out against the former Prime Minister.
However, in 2015, a Special CBI Court rejected those reports and summoned Dr. Singh along with other accused persons. The Supreme Court had stayed the summons the same year, and the appeal remained pending.
Court's Observations
Although Dr. Manmohan Singh passed away in December 2024, the Supreme Court decided to examine the legality of the Special Court's orders because they contained adverse findings against him.
The Bench observed,
"We are satisfied that there were no compelling reasons for the learned Special Judge to turn down the closure reports filed by the CBI and take cognizance."
The Court noted that settled legal principles require courts to carefully assess investigation reports before rejecting them and found that the Special Judge's decision did not meet those standards.
Decision
Allowing the appeal, the Supreme Court set aside the Special Court's orders dated 11 March 2015 and 16 December 2020, accepted both CBI closure reports, and closed the proceedings against Dr. Manmohan Singh on merits.
The Bench clarified that while the appeal could have been treated as infructuous after Dr. Singh's demise, it was necessary to examine the correctness of the orders that had summoned him.
Case Details
Case Title: Dr. Manmohan Singh v. Central Bureau of Investigation & Others
Case Number: Criminal Appeal Nos. 562–563 of 2015
Judge: Chief Justice Surya Kant, Justice Joymalya Bagchi, and Justice V. Mohana
Decision Date: July 29, 2026
