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State Represented by Inspector of Police, CBI, ACB, Visakhapatnam v. Eluri Srinivasa Chakravarthi

Criminal Appeal · 2025 INSC 758Decided 22 May 2025
Crl.A. No.-002784-002794-2025 (arising out of SLP (Crl.) Nos. 5941-5951 of 2022)
Justice Pankaj Mithal · Justice S.V.N. Bhatti

Background

The CBI alleged a large conspiracy in which a Cotton Corporation of India (CCI) purchase officer and his son bought cotton cheaply from real farmers before the government's Minimum Support Price (MSP) was announced, hoarded it, and then resold it to CCI at the higher MSP through dozens of "benami" (front) farmers with forged signatures on weighment slips, causing an alleged loss of over Rs. 21 crore to CCI/the government. Before charges were even framed, the accused got the special court to summon a letter from CCI stating no loss had occurred, and on that basis both the special court and the Andhra Pradesh High Court discharged the accused. The CBI, as appellant, challenged these discharge orders before the Supreme Court.

Decision Breakdown

The Supreme Court held that the special court and High Court committed a fundamental legal error by relying on documents summoned at the accused's instance to justify discharge: settled law (from State of Orissa v. Debendranath Padhi and later cases) holds that at the charge-framing/discharge stage under Section 239 CrPC, only the chargesheet and the documents filed with it by the prosecution can be considered, not material introduced by the defence. The Court found the discharge orders effectively conducted a "mini-trial" and read like an acquittal on merits rather than a proper assessment of whether the chargesheet disclosed a triable case. It set aside the discharge orders and directed the special court to decide afresh, based only on the prosecution's chargesheet and documents, whether the accused should be discharged or charged for trial.

Lesson Learnt

At the stage of framing criminal charges, courts must confine themselves to the prosecution's chargesheet and its accompanying documents: an accused cannot get discharged by introducing their own defence material before trial even begins.

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

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