Bench- Justice S.R. Pandian and Justice K. Jayachandra Reddy.

Facts

Ch. Bhajan Lal, a prominent political figure who had served as both Chief Minister and Union Minister, became the subject of a corruption complaint alleging the illicit accumulation of wealth disproportionate to his known sources of income. The complaint, made by a government official, was forwarded by the Chief Minister’s Secretariat to the Director General of Police, who then instructed the Superintendent of Police to conduct a preliminary inquiry.

Following this direction, the Station House Officer (SHO) registered a First Information Report (FIR) under Sections 161 and 165 of the Indian Penal Code, 1860, along with Section 5(2) of the Prevention of Corruption Act. Bhajan Lal challenged the FIR in the High Court, contending that the allegations were politically motivated, baseless, and did not disclose a cognizable offence.

The High Court accepted his plea and quashed the FIR, observing that the complaint lacked sufficient material to justify a criminal investigation. The State of Haryana, aggrieved by the quashing, approached the Supreme Court, seeking to restore the investigation.

Issues:

1. Whether the High Court was justified in quashing the FIR at the initial stage of investigation?

2. Under what circumstances can a High Court invoke its powers under Article 226 of the Constitution or Section 482 CrPC (now Section 528 Bhartiya Nagarik Suraksha Sanhita, 2023) to quash criminal proceedings?

3. Can an FIR be quashed merely on the ground that the allegations appear politically motivated?

Analysis

• The Purpose and Scope of an FIR- The Court began its analysis by examining the object and scope of an FIR under Section 154 of the CrPC (Section 173, BNSS). It reiterated that an FIR is not an encyclopaedic document. It is meant to set the criminal law in motion. Its primary purpose is to inform the police about the commission of a cognizable offence so that an investigation may begin. Therefore, the threshold for filing an FIR is low — the only requirement is that the information must disclose a prima facie cognizable offence. The Court cautioned that if courts were to quash FIRs on a preliminary reading without investigation, it would stifle genuine prosecutions.

• Limits of Judicial Interference at the Pre- Investigation Stage- A central issue was whether the High Court had erred in quashing the FIR before any meaningful investigation had occurred. The Supreme Court made it clear that interference at such an early stage is highly exceptional and should be exercised only in rarest of rare cases. It stated that High Courts should not act like trial courts by evaluating the evidence or deciding whether the case will ultimately result in conviction.

• Relevancy of Political Motivation- Bhajan Lal argued that the FIR was politically motivated, a common defence by public figures accused of corruption. The Court responded by acknowledging that political vendetta can result in misuse of criminal law, which courts must be vigilant against. However, the Court ruled that mere allegations of malice do not justify quashing an FIR if the complaint discloses a cognizable offence. The Court stated that the motive behind the FIR becomes relevant only after facts are established through investigation and evidence

• Importance of Prima Facie Case and Investigation- One of the most essential takeaways from the judgment is that the credibility of the allegations is not to be judged at the FIR stage. What matters is whether the complaint discloses ingredients of a cognizable offence and whether the allegations, taken on their face value, warrant investigation. In Bhajan Lal’s case, the Court found that allegations of amassing assets disproportionate to income, if proven, would clearly constitute an offence under anti-corruption laws. Therefore, investigation should be allowed to proceed.

• Role of Section 482 CrPC (Section 528, BNSS) and Article 226 of the Constitution- The Court provided an authoritative interpretation of the scope of inherent powers under Section 482 CrPC and Article 226. It emphasized that these powers are not unlimited. Courts must ensure they are used to prevent abuse of the legal process, or secure the ends of justice. The Court warned against using these provisions to intervene routinely, as that would undermine both the police's autonomy and the process of criminal justice. The Court emphasized that if judicial interference becomes too frequent, it may discourage legitimate complaints and embolden wrongdoers.

Judgement:

The Supreme Court allowed the appeal, holding that the High Court erred in quashing the FIR. It ruled that the complaint disclosed cognizable offences, and investigation must proceed in accordance with law.

The Supreme Court laid down specific guidelines for when the High Court could exercise its powers under Section 482 CrPC to quash criminal proceedings. The court identified the following categories where such powers could be exercised:

• 1. Where the allegations do not constitute an offense or make out a case against the accused.
• 2. Where the allegations in the FIR and other materials, if taken at face value and accepted in their entirety, do not prima facie constitute an offense or make out a case against the accused.
• 3. Where the allegations constitute an offense, but there is no evidence to support them.
• 4. Where the FIR does not disclose the commission of an offense, but the allegations, if accepted to be true, constitute a civil dispute with criminal overtones.
• 5. Where the allegations relate to a commercial transaction or a matrimonial dispute and are essentially of a civil nature, with a remote possibility of criminal liability.
• 6. Where there is an express legal bar in the CrPC or the relevant statute to the institution or continuance of the proceedings (e.g., where there is a lack of the required sanction).
• 7. Where a criminal proceeding is manifestly attended with mala fides (malice) and/or where the proceeding is maliciously instituted with an ulterior motive for wreaking vengeance on the accused and with a view to spite him due to private and personal grudge.

Conclusion

State of Haryana v. Bhajan Lal is a landmark decision that the Supreme Court often refers to when deciding whether an FIR should be quashed under Section 482 of the CrPC. In this case, the Court laid down clear guidelines outlining the specific situations in which such quashing is appropriate. It plays a crucial role in drawing a line between the investigative powers of the police and the High Court’s authority to intervene. Importantly, the judgment acts as a safeguard against the misuse of criminal proceedings, making sure they are not weaponized to target individuals unfairly or to pursue personal grudges.