SAJAL BOSE — VERSUS — THE STATE OF WEST BENGAL
1. Document Details:
| Court | Case No | Date | Bench/Parties |
|---|---|---|---|
| Supreme Court of India | CRIMINAL APPEAL NO(S). OF 2026 | April 06, 2026 | Mehta, J. (Sajal Bose vs. The State of West Bengal) |
Executive Overview:
The case concerns appeals by Sajal Bose and others against a High Court order authorising criminal proceedings against them for various alleged offences under the IPC, including assault and intimidation. The Supreme Court quashed the charges against the appellants based on a lack of specific evidence against them, notably considering CCTV footage that did not support the allegations made in the FIR.
Detailed Factual Matrix:
- On 11th October 2022, a complaint was filed by Sushil Chakrabarti after a dispute escalated involving Sourav Sen allegedly breaching a property boundary and verbal altercations ensued.
- The complainant accused the respondents of physical assault and attempting to force their way into his apartment to steal valuables during a heated confrontation.
- The FIR, registered on 18th October 2022, detailed violence involving several IPC sections against eight accused, including the appellants.
- A protest petition contested the omission of additional serious charges in the initial FIR.
- The High Court quashed proceedings against some co-accused but allowed the charges against the appellants to stand, prompting these appeals.
Issues/Charges:
- Whether the allegations in the FIR constitute a prima facie case against the appellants.
- Whether the proceedings against the appellants were initiated with malice or ulterior motives.
- The evidential weight of the CCTV footage relating to the incident.
- The legality of the differential treatment in quashing charges against co-accused but not the appellants.
Submissions of the Parties:
Appellants:
- Argued that proceedings were instigated out of personal animosity, claiming they were peacekeeping during the dispute.
- Asserted that allegations in the FIR were vague and lacked specificity in attributing actions to individual appellants.
- Contended that CCTV footage exonerated them, demonstrating they were not present during the acts alleged in the FIR.
- Claimed the High Court unreasonably differentiated between co-accused without valid justification.
Respondents (Complainant and State):
- Defended the High Court’s decision and the validity of the charges, highlighting credible evidence against the appellants.
- Noted the complainant’s injuries and the involvement of the appellants in the violent episode.
- Argued that the CCTV footage supported the complainant's version of events and corroborated the allegations.
Court’s Detailed Analysis & Reasoning:
- Issue 1: Prima Facie Evidence:
The Court determined that even accepting the complaints in the FIR fully, the allegations against the appellants did not satisfy the necessary legal criteria to constitute a cognizable offence, as physical assaults were not clearly attributed to them.
- Issue 2: Malice:
The Court found strong indications of malice in the proceedings against the appellants, noting the existence of prior disputes between the parties and lack of distinct incriminating acts against the appellants in the complaint.
- Issue 3: CCTV Footage:
Examination of the CCTV footage revealed that the appellants were not present during the critical moments of the altercation, undermining the prosecution's case. The footage showed them attempting to mediate rather than to engage in violence.
- Issue 4: Differential Treatment:
The Court pointed out that the lack of reasoning from the High Court regarding why the co-accused were acquitted while the appellants were not exemplified inconsistency and constituted a failure of justice principle.
Precedents Cited:
- State of Haryana v. Bhajan Lal: Defined categories for quashing proceedings under Section 482 of CrPC, which the Court referenced to assess those against the appellants.
- Pradeep Kumar Kesarwani v. State of Uttar Pradesh: Reinforced the necessity for sound evidence and justificatory reasoning in the exercise of inherent powers to quash criminal proceedings.
Final Outcome/Operative Order:
The Supreme Court allowed the appeals, quashing Charge Sheet No. 135 of 2022 and all charges arising under FIR No. 150 of 2022 against the appellants, deeming the continuation of the proceedings as an abuse of the process of law.