Supreme Court Quashes FIR in Sexual Offences Case, Cautions Against Vexatious Motives

New Delhi, August 8, 2023 - In a significant ruling, the Supreme Court of India today quashed an FIR in a case involving allegations of sexual offences and assault, while cautioning against the potential of vexatious motives behind such filings. The bench comprising of Hon'ble Justice B.R. Gavai and Hon'ble Justice J.B. Pardiwala delivered the judgment, highlighting the importance of scrutinizing FIRs beyond their surface content.

The case, Criminal Appeal No. 2342 of 2023, arose from an order passed by the High Court of Judicature at Allahabad, wherein the appellants challenged the FIR registered against them under Sections 376, 323, and 354(A) of the Indian Penal Code (IPC) and Sections 7 and 8 of the Protection of Children from Sexual Offences Act, 2012. The appellants contended that the allegations lacked specific details and were possibly motivated by personal grudges.

Justice Pardiwala, delivering the judgment, emphasized the need for a close examination of FIRs when invoked to seek quashing. He stated, "Whenever an accused comes before the Court invoking either the inherent powers under Section 482 of the Code of Criminal Procedure or extraordinary jurisdiction under Article 226 of the Constitution to get the FIR or the criminal proceedings quashed, the Court owes a duty to look into the FIR with care and a little more closely."

The Court underlined the significance of looking beyond the mere averments in an FIR, suggesting that Courts should consider the overall circumstances and potential motives that might not be explicitly stated. Justice Pardiwala noted, "The Court while exercising its jurisdiction under Section 482 of the CrPC or Article 226 of the Constitution need not restrict itself only to the stage of a case but is empowered to take into account the overall circumstances leading to the initiation/registration of the case as well as the materials collected in the course of investigation."

The bench acknowledged that, in some cases, personal grudges or private vendettas might underlie the registration of multiple FIRs. Accordingly, the Court allowed the appellants to file a discharge application under Section 227 of the Code of Criminal Procedure before the Trial Court, emphasizing that the Trial Court should take a closer look at the materials collected during the investigation.

The judgment highlights the Court's commitment to preserving justice while guarding against potential misuse of the legal system for personal vendettas. It serves as a reminder that the judiciary plays a crucial role in ensuring fairness and protecting the integrity of legal proceedings.

Date of Decision: August 8, 2023

IQBAL @ BALA & ORS. vs STATE OF U.P. & ORS.