Narayana Health v. State of West Bengal 2026 INSC 481 - IPC - Complaint Quashed
Indian Penal Code - Section 405 - In the absence of entrustment, dishonest misappropriation, or violation of a fiduciary obligation, foundational ingredients of the offence of criminal breach of trust are not satisfied. (Para 11) Section 420 -For the offence of cheating under Section 420, IPC there must be deception on part of the accused from the very beginning; such deception must lead to fraudulent or dishonest inducement; and the accused must have had dishonest intention at the time the inducement was made (Para 12) - Section 120B - For the offence of criminal conspiracy under Section 120B, IPC there must be a prior agreement or meeting of minds for commission of an illegal act or a lawful act by illegal means. (Para 13)
Case Info
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Case name:Narayana Health & Ors. v. State of West Bengal & Ors.
Neutral citation:2026 INSC 481
Coram:Justice Pamidighantam Sri NarasimhaJustice Alok Aradhe
Judgment date:12 May 2026 (NEW DELHI)
Case laws and citations referred:
- State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335
- Ramesh Chandra Gupta v. State of UP, (2022) 18 SCC 706
- Arshad Neyaz Khan v. State of Jharkhand, 2025 SCC OnLine SC 2058
- Shashank Garg v. State and Ors., 2025 SCC OnLine Del 2455
- Sadhupati Nageswara Rao v. State of Andhra Pradesh, (2012) 8 SCC 547
- Prof. R.K. Vijayasarathy v. Sudha Seetharam, (2019) 16 SCC 739
- Joseph Salvaraj A. v. State of Gujarat, (2011) 7 SCC 59
- Ajay Mitra v. State of M.P., (2003) 3 SCC 11
- Alpic Finance Ltd. v. P. Sadasivan, (2001) 3 SCC 513
- State (NCT of Delhi) v. Navjot Sandhu, (2005) 11 SCC 600
- R.K. Vijayasarathy v. Sudha Seetharam, (2019) 16 SCC 739 (re‑referred for conspiracy principle)
Statutes / laws referred:
- Indian Penal Code, 1860
- Section 405 (criminal breach of trust – discussed as 405 though complaint invoked 406)
- Section 406 (criminal breach of trust – as invoked in complaint)
- Section 420 (cheating)
- Section 120B (criminal conspiracy)
- Section 503 (criminal intimidation – mentioned contextually)
- Section 504 (intentional insult with intent to provoke breach of the peace – considered by High Court)
- Code of Criminal Procedure, 1973
- Section 200
- Section 482
- Sections 155(2), 156(1) (through Bhajan Lal extract)
- West Bengal Clinical Establishments (Registration, Regulation and Transparency) Act, 2017
- Section 7(3)(c), (e), (g), (l), (m), (n), (o), (p)
- Section 29
- Section 34
- Sections 35 and 36
- Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002
Three-sentence brief summary:The Supreme Court held that a complaint against Narayana Health and its officials over an incorrect HRCT charge of Rs. 2,500 and alleged non‑supply of records did not disclose the essential ingredients of criminal breach of trust, cheating, or criminal conspiracy, especially since the hospital corrected the bill and offered a refund. It further found that the High Court erred in remanding the case after casually observing that an offence under Section 504 IPC was made out, without a clear factual or legal foundation, and that grievances regarding billing and medical records are primarily to be addressed through the remedial and adjudicatory scheme of the West Bengal Clinical Establishments Act, 2017. Exercising powers under Section 482 CrPC, the Court quashed the criminal complaint, clarifying that this would not affect any civil or statutory remedies available to the complainant.