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Criminal · Reportable judgment

State Rep. By The Deputy Superintendent of Police, Vigilance and Anti Corruption Chennai City-I Department vs G. Easwaran

Court
Supreme Court of India
Date
26 March 2025
Case No.
Criminal Appeal No. 1405 of 2019
Result
Allowed
Bench
Pamidighantam Sri Narasimha, Manoj Misra
Citation
[2025] 3 S.C.R. 1174 : 2025 INSC 397
Acts & Sections
Prevention of Corruption Act, 1988 CrPC
Supreme Court Reports [2025] 3 S.C.R. 1174 : 2025 INSC 397
Issue for consideration
The High Court quashed the criminal proceedings against the respondent u/s.13(2) r/w. s.13(1)(e) of the Prevention of Corruption Act, 1988 for possessing assets disproportionate to known sources of income while exercising jurisdiction u/s.482 of the Code of Criminal Procedure, 1973.
Headnote

Prevention of Corruption Act, 1988 – s.13(2) r/w. s.13(1)(e) – Allegation that appellant was hoarding assets disproportionate to his income – FIR registered u/ss.13(2) r/w. s.13(1)(e) of the PC Act – State Government granted sanction to prosecute the respondent – After investigation, charge-sheet was filed – Discharge application filed by the respondent – Application dismissed by the Special Court – Revision Petition was also dismissed by the High Court – However, respondent again filed a petition u/s.482 CrPC within 7 months before the High Court virtually on same grounds – This time, the High Court quashed criminal proceedings u/s.13(2) r/w. s.13(1)(e) of the PC Act – Correctness:

Held: It is not disputed that in the instant case, the Special Court, as well as the High Court, while dismissing the petition for discharge, examined the allegations and arrived at clear findings that there was a prima facie case against the respondent – The impugned order revisits the earlier decisions without any statable change in the facts and circumstances of the case, traverses to the extreme end of the spectrum – It is clear that the High Court jumped to the probable conclusion of trial by not appreciating the limited scope of s.482 CrPC – Apart from being congruent and overlapping, the respondent could not demonstrate any material change in facts and circumstances between the dismissal of the revision petition by the High Court and the filing of the quashing petition u/s.482 CrPC – As far as the validity of sanction is concerned, the validity of the sanction can always be examined during the course of the trial and the problems due to the typographical error as alleged by the State could have been explained by producing the file at the time of trial – It is settled that a mere delay in the grant of sanction for prosecuting a public authority is not a ground to quash a criminal case – Thus, the reasoning adopted by the High Court for interdicting the criminal proceedings is contrary to the well-established principles laid down by this Court. [Paras 10, 14, 15]

Keywords: Disproportionate assets · Discharge application · Change in the facts and circumstances of the case · Scope of section 482 of Code of Criminal Procedure, 1973 · Government’s sanction to prosecute public authority · Validity of sanction · Course of trial

As published in the Supreme Court Reports, Supreme Court of India. Headnotes prepared by: Ankit Gyan. Text from the Indian Supreme Court Judgments open data set (Dattam Labs), CC BY 4.0.

Full Judgment Text

Judgment Pamidighantam Sri Narasimha, J. 1. This appeal arises out of the final judgment of the High Court of Madras1, by which criminal proceedings against the respondent under Section 13(2) read with Section 13(1)(e) of the Prevention of Corruption Act, 19882 for possessing assets disproportionate to known sources of income were quashed while exercising jurisdiction under Section 482 of the Code of Criminal Procedure, 19733. 2. Facts: The relevant facts are that the respondent joined government service as a surveyor in 1980 and was working as Assistant Director with Nagercoil Local Planni
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