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Sanjay Dutt v. State of Haryana

Criminal Appeal · 2025 INSC 34Decided 2 Jan 2025
Crl.A. No.-000011-000011 - 2025
Justice J.B. Pardiwala · Justice R. Mahadevan

Background

A Range Forest Officer in Gurugram lodged a complaint alleging that trees had been illegally uprooted using a JCB machine at a construction site, in violation of Section 4 of the Punjab Land Preservation Act, 1900. The complaint named as accused three individuals (a project manager, a general manager, and the appellant Sanjay Dutt (a company director)) none of whom were alleged to have personally uprooted the trees. The High Court of Punjab and Haryana refused to quash the complaint, so the accused appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that criminal vicarious liability cannot be imputed to a company's directors or officers unless the statute itself specifically provides for it, and the 1900 Act contains no such provision. The complaint contained no specific allegation that any of the three appellants personally participated in or directed the tree-felling: the actual workers who felled the trees were never even named as accused, and the company itself was not arrayed as an accused. The Court found the allegations against the appellants "absolutely vague" and held that the trial court should never have taken cognizance and issued process against them. The appeal was allowed and the complaint and the order taking cognizance were quashed, while clarifying that authorities remain free to proceed against the company itself for any licence violations.

Lesson Learnt

Being a director or manager of a company does not automatically make a person criminally liable for the company's acts. Vicarious criminal liability only arises where a specific law provides for it and where the complaint makes concrete, specific allegations connecting that individual's personal conduct to the offence, not just their job title.

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

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