Criminal proceedings must be quashed where unimpeachable material (CCTV footage) negates the accused’s participation and allegations remain vague and mala fide.
Facts
Neighbourhood dispute escalating into criminal prosecution
The case arose from an altercation on 11 October 2022 between residents of an apartment complex. The complainant alleged that multiple accused, including the appellants, formed an unlawful assembly and assaulted him and his family, invoking offences under S. 143, 341, 323, 324, 504, 506, 509, 427, 354 IPC.
A chargesheet was filed and cognizance taken. The High Court partly quashed proceedings against some co-accused but allowed continuation against the appellants. The appellants challenged this refusal before the Supreme Court.
Issues Framed
Whether continuation of criminal proceedings against the appellants is justified in light of S. 482 CrPC principles governing quashing, particularly when CCTV evidence allegedly negates their involvement.
Court’s Reasoning
(a) Legal Standard (Quashing Jurisdiction)
The Court reiterated the test in State of Haryana v. Bhajan Lal, emphasizing that proceedings may be quashed where allegations “even if taken at their face value… do not prima facie constitute any offence” or are “manifestly attended with mala fide” (Para 22–23).
(b) Assessment of FIR and Allegations
The Court held that the FIR contained “vague” and “generalized allegations” without specific attribution of overt acts to the appellants (Para 24–25).
(c) Primacy of CCTV Evidence
Upon examining CCTV footage, the Court found:
“the appellants are not visible at the scene during the relevant time when the alleged acts of assault… took place” and instead “appear only subsequently… to placate the situation” (Para 27).
This “materially undermines the prosecution’s case” and renders allegations “highly doubtful and unworthy of credence even at the stage of quashing” (Para 27).
(d) Failure of High Court
The High Court failed to consider this crucial electronic evidence and also unjustifiably distinguished similarly placed co-accused, rendering its reasoning unsustainable (Para 28–29).
(e) Application of Four-Step Test (Pradeep Kumar Kesarwani)
The CCTV footage was held to be of “sterling and impeccable quality”, sufficient to negate allegations and incapable of refutation (Para 33).
(f) Conclusion on Abuse of Process
The Court held that continuation of proceedings would amount to “misuse of the criminal process” where no credible material connects the accused (Para 34).
Held
The Supreme Court allowed the appeals, set aside the High Court judgment, and quashed the chargesheet and criminal proceedings against the appellants.
Ratio
Where unimpeachable evidence (such as CCTV footage) negates the accused’s involvement and allegations lack specific attribution, continuation of proceedings constitutes abuse of process and must be quashed under S. 482 CrPC (Para 31–33).
Case Details
Citation: 2026 INSC 322
Decided on: 06 April 2026
Case Title: Sajal Bose v. State of West Bengal & Ors.
Court: Supreme Court of India
Bench: Vikram Nath, Sandeep Mehta, N. V. Anjaria, JJ.