The Supreme Court’s ruling clarifies the limitations of High Court powers under Section 482 CrPC, emphasizing the role of investigation reports.
Case in News:
The Supreme Court of India stated that the High Court cannot rely on the investigation report under Section 482 CrPC powers .
Case Overview:
Case Name: Ashok Kumar Jain versus The State of Gujarat and Another.
In the case of Ashok Kumar Jain v. State of Gujarat a Supreme Court bench of Justice Pankaj Mithal and Justice SVN Bhatti delivered a landmark ruling relating to Section 482 CrPC . The Gujarat High Court had earlier refused to quash criminal proceedings against the appellant relying heavily on the investigation report . The Supreme Court of India set aside this decision by explaining that High Courts cannot assess or rely upon an investigation report while deciding petitions for quashing FIRs under Section 482 CrPC For Quashing Of Criminal Proceedings . The Supreme Court cited the precedent of Pratibha v. Rameshwari Devi (2007) to reinforce its stance .
Key Aspects :
- The appellant sought quashing of a criminal case under Section 482 of Criminal Procedure Code (CrPC) .
- The Gujarat High Court relied on the police investigation report in its refusal .
- The Supreme Court of India reaffirmed the limited scope of powers of the High Court under Section 482 CrPC .
- The ruling stressed the exclusive authority of the Magistrate to assess investigation reports .
Legal Insights :
- Section 482 CrPC For Quashing Of Criminal Proceedings limits High Court intervention to FIR allegations and undisputed facts .
- Cited case law : Pratibha v. Rameshwari Devi (2007) 12 SCC 369 .
- The Supreme Court of India reiterated that investigation reports are meant solely for the consideration of the Magistrate
- Highlighted the principle that High Court’s extraordinary powers must be used sparingly .
Court’s Verdict:
The Supreme Court of India held that the High Court’s reliance on the investigation report was impermissible under Section 482 CrPC . It quashed the pending criminal case against the appellant by setting aside the order of the Gujarat High Court .
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