The Supreme Court has underscored the significance of refraining from prematurely staying or quashing criminal trials, as such actions could undermine the evidence that needs to be presented before the trial court. The Court remarked, “Courts must avoid the premature staying or quashing of criminal trials at the preliminary stage since such a measure may cause great damage to the evidence that may have to be adduced before the appropriate trial court.”
In the present matter, the bench comprising Justices J.B. Pardiwala and Manoj Misra reversed the Madhya Pradesh High Court's decision, which had quashed a criminal case against police officers accused of fabricating documents to create an alibi for an accused in a murder case. The High Court had based its decision on the absence of prior sanction under Section 197 of the Criminal Procedure Code (Cr.P.C.) for prosecuting the police officers.
The Supreme Court found the High Court's approach flawed, emphasizing that the case against the public servants was at a preliminary stage. It was held that quashing the case at this juncture would be inappropriate, as evidence must be presented before the trial court to determine whether the alleged actions of the police officers fell within the scope of their official duties.
In its analysis, the Court relied on established legal precedents, concluding that fabricating documents does not form part of the official duties of public servants. Accordingly, no prior sanction under Section 197 Cr.P.C. was required to prosecute the accused officers.
The judgment, authored by Justice Pardiwala, further clarified that the applicability of Section 197 Cr.P.C. must be determined based on the specific facts and circumstances of each case. The Court explained that acts such as fabricating documents, providing false statements, illegally detaining individuals, or engaging in other unlawful conduct fall outside the protective scope of Section 197 Cr.P.C. The Court reasoned that allowing public servants to carry out illegal acts under the guise of official duties would enable them to misuse their positions and exploit their status to commit objectionable or unlawful activities. Such an interpretation, the Court noted, would defeat the principles of justice.
Consequently, the Supreme Court allowed the appeal and directed that the trial against the accused police officers should proceed. This decision reiterates the principle that public servants cannot seek immunity for actions that are outside the scope of their lawful duties.
Cause Title: Om Prakash Yadav Vs Niranjan Kumar Upadhyay & Ors
