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Sanju Rajan Nayar vs. Jayaraj

Not available · 2024 INSC 331Decided 23 Apr 2024
Not available
Justice Sanjay Karol · Justice Prasanna Bhalachandra Varale

Background

The appellant's minor child had been allegedly sexually harassed, leading to an FIR against a third party under the POCSO Act. During that investigation, the appellant alleged that the investigating officer (respondent no. 2) and a police inspector (respondent no. 1, Jayaraj) demanded and accepted bribes from him, including money for a favourable chargesheet and weekly payments as a bail condition, evidence of which he gave to the Karnataka Human Rights Commission, including a pendrive recording. This led to a corruption case against the two police officers, but the Karnataka High Court quashed the FIR against Jayaraj, holding there was no direct evidence he had personally demanded a bribe.

Decision Breakdown

The Supreme Court held that the High Court's approach in quashing the FIR at such an early stage was legally unsustainable, as it improperly conducted a mini-trial and evaluated evidence (like "no direct evidence of demand") that should be tested during investigation and trial, not decided prematurely: contrary to the settled principles from State of Haryana v. Bhajan Lal on when FIRs can be quashed. It noted the pendrive evidence had not been properly accounted for, that the competent authority had still sanctioned prosecution despite the officer's exoneration in a separate departmental inquiry, and that the departmental proceedings had not even been on the same evidence as the criminal case. The Court allowed the appeal, quashed the High Court's order, and restored the FIR to proceed to its logical conclusion, leaving all factual and legal contentions open for trial.

Lesson Learnt

Courts should be cautious about quashing a corruption FIR at a preliminary stage by weighing evidence as if conducting a trial: that kind of assessment belongs to the investigation and trial process, not to an early petition to quash.

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

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