Kiran Raj

The Rajasthan High Court has quashed criminal proceedings against the directors and medical staff of Goyal Hospital & Research Centre, Jodhpur, accused of manipulating pathology reports and engaging in dishonest practices related to the treatment of a deceased patient. The Court held that the evidence presented did not substantiate the charges of forgery and cheating under the Indian Penal Code (IPC) and observed that the cognizance taken by the lower courts lacked necessary judicial scrutiny.

The case stemmed from a complaint lodged by the family of a deceased patient, alleging that the hospital staff and directors had falsified pathology reports to cover up medical negligence. The complainant argued that such actions amounted to criminal offenses under Sections 467 (forgery of valuable security), 468 (forgery for the purpose of cheating), 471 (using a forged document as genuine), and 420 (cheating) of the IPC.

Following an investigation, the police filed a charge sheet implicating the hospital’s directors and staff. The accused moved the Rajasthan High Court, seeking to quash the criminal proceedings. They contended that the allegations were unsubstantiated and maliciously motivated, aimed at tarnishing their professional reputation.

The petitioners argued that the essential ingredients of forgery and cheating were absent in the case. They submitted that the complainant failed to present evidence showing that the alleged manipulation of reports was done with fraudulent intent to deceive or cause wrongful loss. They also contended that the lower courts had taken cognizance of the case without proper examination of the facts and legal requirements.

On the other hand, the complainant alleged that the manipulation of pathology reports had directly influenced the deceased patient’s treatment, leading to a fatal outcome. The complainant maintained that the acts of the hospital staff constituted criminal conduct, warranting prosecution to ensure accountability.

The Rajasthan High Court examined the charge sheet, supporting documents, and arguments advanced by both parties. Justice Sanjeev Prakash Sharma noted that the investigation failed to establish any direct link between the alleged falsification of pathology reports and the outcome of the patient’s treatment. The Court stated:

"For the offence of forgery under Sections 467 and 468 IPC to be made out, there must be credible evidence indicating that the accused forged a document with the intent to cause wrongful gain, wrongful loss, or harm to another person."

The Court observed that the allegations lacked the evidentiary foundation required to constitute offenses under Sections 467, 468, 471, or 420 IPC. It further noted:

"There is no material on record to suggest that the accused acted with the requisite criminal intent necessary to constitute the offences of forgery, cheating, or conspiracy under the IPC."

The Court criticized the lower courts for failing to conduct a thorough judicial examination of the facts before taking cognizance of the case. It stated:

"Judicial scrutiny at the stage of cognizance is essential to prevent unwarranted criminal prosecution. Courts must ensure that there is sufficient prima facie evidence to substantiate the charges before subjecting individuals to criminal proceedings."

The Court noted the importance of distinguishing professional misconduct from criminal culpability and remarked:

"Errors or lapses in professional conduct may attract civil or regulatory liability but cannot be equated with criminal offenses unless accompanied by clear evidence of fraudulent intent."

The Court stated that criminal proceedings must not be initiated without credible evidence, particularly against professionals; as such actions can cause irreparable damage to their reputation and livelihood.

The Rajasthan High Court quashed the criminal proceedings against the accused and directed the closure of the case. The Court stated that judicial and investigative agencies must exercise caution while handling complaints involving professionals. It stated:

"The misuse of criminal law as a tool for harassment must be curtailed. Investigative agencies must conduct a detailed inquiry before filing charge sheets, and courts must rigorously examine allegations before taking cognizance."

The Court stated that criminal liability should only be imposed where there is clear and credible evidence of fraudulent intent or malafide action.

Case Title: The State of Rajasthan & Ors. v. Goyal Hospital & Research Centre & Ors.
Case Number: S.B. Criminal Miscellaneous Petition No. 1480/2024
Bench: Justice Sanjeev Prakash Sharma

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