SAJAL BOSE VERSUS THE STATE OF WEST BENGAL AND ORS., 2026
The Court reinforced the principle that Courts can exercise inherent powers to prevent injustice and abuse of process.
Judgement Details
Court
Supreme Court of India
Date of Decision
8 April 2026
Judges
Justice Vikram Nath & Justice Sandeep Mehta & Justice NV Anjaria
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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The case arose from a dispute in an apartment complex in Kolkata (October 2022).
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A 77-year-old complainant alleged assault and threat by several individuals, leading to registration of FIR under multiple IPC provisions.
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The Calcutta High Court quashed proceedings against two co-accused for lack of specific allegations but refused relief to the three appellants.
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The appellants approached the Supreme Court, arguing that the prosecution failed to rebut CCTV evidence contradicting the complainant’s version.
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The CCTV footage showed that the appellants were pacifying the situation rather than participating in violence, which was not countered by the prosecution.
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The Supreme Court examined the footage and found it credible and unimpeachable, undermining the factual basis of the complaint.
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Applying the Pradeep Kumar Kesarwani test, the Court concluded that continuing proceedings would be an abuse of the criminal process.
Issues
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Whether the Supreme Court can quash criminal proceedings when credible and unimpeachable material displaces the factual basis of allegations?
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Whether CCTV footage showing appellants pacifying a situation, if unrefuted by prosecution, justifies quashing proceedings?
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Whether the continuation of trial in absence of credible material amounts to misuse of the criminal process?
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Whether the Pradeep Kumar Kesarwani test under Section 482 CrPC is applicable in determining quashing of criminal proceedings?
Held
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Criminal proceedings against the appellants are quashed.
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Unrefuted and credible evidence can justify quashing of proceedings under Section 482 CrPC.
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CCTV footage demonstrating lack of participation in alleged crime is sufficient to dislodge the factual foundation of accusations.
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Continuation of trial in such circumstances would constitute misuse of criminal process.
Analysis
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The Court reinforced the principle that Courts can exercise inherent powers to prevent injustice and abuse of process.
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It highlighted the importance of credible, unimpeachable evidence, such as CCTV footage, in evaluating the merits of criminal allegations at the outset.
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The judgment clarified that prosecution must effectively counter exculpatory material; failure to do so can justify quashing.
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Applying the Pradeep Kumar Kesarwani steps, the Court demonstrated a structured approach to quashing petitions under Section 482 CrPC.
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This case impacts future quashing petitions, particularly where video or documentary evidence discredits the complaint, emphasizing early judicial intervention to prevent unnecessary trials.