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Maneesha Yadav & Ors. vs. The State of Uttar Pradesh & Anr.

Not available · 2024 INSC 322Decided 9 Apr 2024
Not available
Justice B.R. Gavai · Justice Prashant Kumar Mishra

Background

A nursing college in Gorakhpur had permission to admit only 40 students but admitted 60, and when results of the extra 20 students were withheld, several students filed complaints, leading to an FIR for cheating and forgery. The three appellants (the wife, sister, and an employee of the institute's Director/Manager) were roped into the FIR solely because of their relationship to the actual office-bearers, with no specific allegation that they induced or cheated anyone. The Allahabad High Court refused to quash the FIR against them, reasoning they could instead seek discharge at trial.

Decision Breakdown

The Supreme Court held that merely being a close relative (wife, sister) or an employee of the institute's management, without any specific allegation of personal inducement or involvement in the fraud, does not justify continuing criminal proceedings. Applying the guidelines from State of Haryana v. Bhajan Lal, the Court found the FIR, even taken at face value, disclosed no offence against these three appellants and quashed both the FIR and the connected proceedings under the U.P. Gangsters Act. The Court also held that mere filing of a charge-sheet does not bar the High Court from exercising its Section 482 CrPC powers.

Lesson Learnt

Being related to, or employed by, someone accused of a crime does not by itself make a person criminally liable: the FIR must specifically show what that individual actually did.

Official source (sci.gov.in)View Judgment (PDF)

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