Supreme Court Restores Corruption FIR Holding High Court Exceeded Its Powers Under Section 482 CrPC

In Sanju Rajan Nayar v. Jayaraj & Anr. (2024 Latest Caselaw 264 SC), the Supreme Court restored an FIR registered under the Prevention of Corruption Act, 1988, holding that the High Court had exceeded its jurisdiction under Section 482 of the Code of Criminal Procedure by prematurely evaluating the evidence. The Court reiterated that disputed questions of fact and the sufficiency of evidence cannot ordinarily be examined while considering a petition for quashing an FIR. 

The appellant was facing criminal proceedings under the Protection of Children from Sexual Offences Act, 2012, based on a complaint lodged by his wife. During the investigation, he alleged that the investigating police officers demanded and accepted illegal gratification in return for filing a favourable charge sheet and for extending favourable treatment during the investigation. The appellant reported the matter to the Karnataka Human Rights Commission and produced electronic evidence, including a pen drive. Following a preliminary enquiry, an FIR was registered under Section 7(a) of the Prevention of Corruption Act against two police officers. The competent authority also granted sanction for prosecution. However, the Karnataka High Court quashed the FIR against one of the accused under Section 482 CrPC, holding that there was no direct evidence of demand for bribe and that the complaint appeared to have been filed as retaliation for the criminal case pending against the appellant. The appellant challenged the High Court's order before the Supreme Court. 

The principal issue was whether the High Court was justified in quashing the FIR under Section 482 CrPC by assessing the sufficiency of the evidence at the investigation stage.

The Supreme Court held that the High Court had travelled beyond the permissible scope of its jurisdiction under Section 482 CrPC. The Court observed that:

•The FIR specifically alleged the involvement of the respondent in demanding illegal gratification. 

•Material collected during the preliminary investigation, including the electronic evidence in the form of a pen drive, could not be ignored at the threshold. 

•The High Court wrongly undertook an assessment of the evidence by concluding that there was no direct proof of demand for a bribe. 

•The fact that the respondent had been exonerated in departmental proceedings did not automatically justify quashing the criminal proceedings, particularly when the competent authority had granted sanction for prosecution. 

•The Lokayukta had specifically contended that the criminal prosecution was based on material different from that considered during the departmental enquiry. 

•The High Court failed to apply the principles governing quashing of criminal proceedings laid down by the Supreme Court in State of Haryana v. Bhajan Lal. The Court held that such factual issues must be examined during investigation or trial and not while exercising inherent jurisdiction under Section 482 CrPC. 

The Supreme Court:

•Allowed the appeal. 

•Set aside the judgment of the Karnataka High Court. 

•Restored the FIR registered under the Prevention of Corruption Act. 

•Directed that the investigation and subsequent proceedings continue in accordance with law. 

•Clarified that all questions of fact and law remain open to be decided at the appropriate stage. 

The judgment reinforces the limited scope of the High Court's inherent powers under Section 482 CrPC. It reiterates that courts should not evaluate the sufficiency or reliability of evidence while considering a petition to quash an FIR. The decision also clarifies that exoneration in departmental proceedings does not automatically bar criminal prosecution, particularly where independent material exists to justify investigation or trial under the Prevention of Corruption Act.