Supreme Court overturns High Court order quashing criminal proceedings in assault case: Satish Kumar Jatav vs. State of U.P. (2022)

Date of the Judgment: May 17, 2022

Citation: (2022) INSC 509

Judges: M. R. Shah, J. and B.V. Nagarathna, J.

Can a High Court quash criminal proceedings without providing clear reasons? The Supreme Court of India recently addressed this question in a case where the High Court of Judicature at Allahabad had quashed a criminal case without a detailed explanation. The Supreme Court, in this instance, emphasized the necessity for High Courts to provide reasoned orders, especially when overturning a lower court’s decision to summon accused persons for trial. The bench, comprising Justices M.R. Shah and B.V. Nagarathna, overturned the High Court’s order, reinstating the trial court’s decision.

Case Background

The appellant, Satish Kumar Jatav, initially filed an application under Section 156(3) of the Code of Criminal Procedure, 1973, because the local police did not register a First Information Report (FIR) regarding an incident that occurred on September 11, 2004. The incident involved allegations of assault and offences under the Indian Penal Code, 1860 and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

On October 4, 2004, the Magistrate directed the police to register an FIR. Subsequently, the police submitted a closure report, which the complainant protested, alleging collusion between the police and the accused. The complainant then filed a criminal complaint case.

The Magistrate rejected the police’s closure report on July 21, 2005, merging the police proceedings with the criminal complaint case. After recording statements of the complainant and witnesses, the Magistrate issued summons on February 4, 2008, directing the accused to face trial for offences under Sections 307, 504, and 506 of the Indian Penal Code, 1860, and Section 3(10)(15) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The accused then approached the High Court of Judicature at Allahabad, seeking to quash the criminal proceedings under Section 482 of the Code of Criminal Procedure, 1973. The High Court allowed the application, quashing the proceedings, which led to the present appeal before the Supreme Court.

Timeline:

Course of Proceedings

The High Court of Judicature at Allahabad, in a cryptic one-paragraph order, quashed the criminal proceedings initiated by the Magistrate. The High Court did not provide any detailed reasoning for its decision, which was challenged by the complainant in the Supreme Court. The High Court’s decision was based on the submissions made by the counsels of the parties and a general observation that prolonging the proceedings would not serve any useful purpose.

Legal Framework

The case involves several key legal provisions. Section 482 of the Code of Criminal Procedure, 1973, grants the High Court inherent powers to prevent abuse of the process of any court or to secure the ends of justice. The High Court invoked this power to quash the proceedings initiated by the Magistrate.

The offences alleged against the accused are under Sections 307 (attempt to murder), 504 (intentional insult with intent to provoke breach of the peace), and 506 (criminal intimidation) of the Indian Penal Code, 1860, and Section 3(10)(15) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

Section 3(10) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, pertains to intentionally insulting or intimidating with intent to humiliate a member of a Scheduled Caste or a Scheduled Tribe in any place within public view. Section 3(15) of the same Act deals with assaulting or using force against any member of a Scheduled Caste or Scheduled Tribe.

Arguments

Appellant’s Arguments (Original Complainant):

• The counsel for the original complainant argued that the High Court’s order was cryptic and non-reasoned.
• It was submitted that the High Court did not independently apply its mind to the case.
• The Magistrate had issued summons after considering statements under Sections 200 and 202 of the Code of Criminal Procedure, 1973, and the injury report.
• The High Court should not have interfered with the Magistrate’s order under Section 482 of the Code of Criminal Procedure, 1973.

Respondents’ Arguments (Original Accused):

• The counsel for the original accused supported the High Court’s judgment.
• It was contended that the High Court had considered the facts and circumstances of the case.
• The High Court had also considered the submissions made by the parties.
• It was argued that the Supreme Court should not interfere with the High Court’s order under Article 136 of the Constitution of India.

State’s Arguments:

• The counsel for the State adopted the submissions made by the complainant.

Issues Framed by the Supreme Court

✓ Whether the High Court was justified in quashing the criminal proceedings in exercise of powers under Section 482 of the Code of Criminal Procedure, 1973.

✓ Whether the High Court’s order was a reasoned order.

Treatment of the Issue by the Court

Authorities

The Supreme Court did not cite any specific cases in its judgment. However, it emphasized the principle that High Courts must pass speaking and reasoned orders, especially when exercising their powers under Section 482 of the Code of Criminal Procedure, 1973.

The Court considered the following legal provisions:

• Section 482 of the Code of Criminal Procedure, 1973: This section deals with the inherent powers of the High Court. The Court noted that while the High Court has the power to quash proceedings to prevent abuse of process or secure the ends of justice, this power must be exercised judiciously and with proper reasoning.
• Sections 307, 504, and 506 of the Indian Penal Code, 1860: These sections pertain to the offences of attempt to murder, intentional insult with intent to provoke breach of the peace, and criminal intimidation, respectively.
• Section 3(10)(15) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989: These sections deal with offences related to insulting or intimidating a member of a Scheduled Caste or Scheduled Tribe and assaulting or using force against such a member.

Judgment

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the lack of reasoning in the High Court’s order. The Court emphasized that High Courts must provide detailed explanations when exercising their inherent powers, especially when overturning a lower court’s decision. The Court found that the High Court had not independently applied its mind to the case and had not addressed the legality and validity of the Magistrate’s order. The Supreme Court was also concerned that the High Court had quashed the proceedings based on the premise that prolonging the proceedings would not serve any purpose, which the Supreme Court stated is not a valid ground for quashing criminal proceedings.

The Supreme Court did not consider any alternative interpretations. The Court’s reasoning was straightforward: the High Court’s order lacked the necessary reasoning and independent application of mind required for such decisions. The decision was reached by applying established principles regarding the exercise of inherent powers by the High Court.

The Supreme Court held that the High Court’s order was unsustainable because it was a cryptic, non-speaking order that did not address the legality and validity of the Magistrate’s order. The Supreme Court restored the order passed by the learned Magistrate summoning the accused.

The Supreme Court quoted the following from the High Court’s order:

“Considering the facts and circumstances of the case, as noted hereinabove, and also the submissions made by the counsel for the parties, the court is of the considered opinion that no useful purpose shall be served by prolonging the proceedings of the above mentioned case.”

The Supreme Court stated that the High Court’s observation that “no useful purpose will be served by prolonging the proceedings” cannot be a ground to quash the criminal proceedings when a clear case was made out.

Key Takeaways

• High Courts must provide reasoned and speaking orders when exercising their inherent powers under Section 482 of the Code of Criminal Procedure, 1973.
• Quashing criminal proceedings requires a detailed assessment of the facts and circumstances of the case.
• The mere observation that prolonging proceedings would serve no useful purpose is not a valid ground to quash criminal proceedings.
• The Supreme Court has emphasized the importance of a thorough and reasoned approach by the High Courts in such matters.

Directions

The Supreme Court quashed the High Court’s order and restored the order passed by the Magistrate summoning the accused.

Development of Law

The ratio decidendi of this case is that High Courts must provide reasoned and speaking orders when exercising their inherent powers under Section 482 of the Code of Criminal Procedure, 1973, especially when overturning a lower court’s decision. This judgment reinforces the principle that the High Court’s inherent powers are not to be exercised arbitrarily and that there must be a detailed assessment of the facts and circumstances of the case while quashing criminal proceedings. This judgment does not change the previous position of law, but rather reinforces the existing principles.

Conclusion

The Supreme Court’s decision in Satish Kumar Jatav vs. The State of U.P. & Ors. underscores the importance of reasoned judicial orders, particularly in cases involving the quashing of criminal proceedings. The Court’s emphasis on the need for High Courts to provide detailed justifications for their decisions reinforces the principles of transparency and accountability in the judicial process. The Supreme Court overturned the High Court’s decision and restored the Magistrate’s order, ensuring that the accused would face trial for the alleged offences.