Sajal Bose v. State of West Bengal 2026 INSC 322 - S 482 CrPC

Code of Criminal Procedure 1973 - Section 482 - Where reliable and unimpeachable material demonstrably displaces the factual basis of the accusations and the prosecution is unable to effectively counter the same, the Court would be justified in invoking its inherent jurisdiction to prevent injustice. Such an approach not only accords justice to the accused but also obviates the wastage of precious judicial time on proceedings which, on the admitted material, do not hold a reasonable prospect of culminating in conviction. [Context: The Supreme Court considered appeals by three accused seeking quashing of criminal proceedings arising from a neighbourhood altercation in a Kolkata apartment complex, where they were alleged to have assaulted and threatened a 77‑year‑old complainant and his family. Applying the Bhajan Lal categories and the four‑step test in Pradeep Kumar Kesarwani, the Court closely examined the CCTV footage (forming part of the chargesheet) and found that it did not show the appellants participating in any assault, but rather arriving later and attempting to pacify the situation, with the allegations against them remaining vague, omnibus and unsupported by specific overt acts. Holding that the case fell within categories (1), (3) and (7) of Bhajan Lal and that continuing the prosecution would be an abuse of process, the Court set aside the Calcutta High Court’s order and quashed the chargesheet and proceedings against the three appellants.]