CBI vs. Aryan Singh: Supreme Court Restores Criminal Proceedings

The case of Central Bureau of Investigation vs. Aryan Singh & Others is a crucial ruling by the Supreme Court of India, addressing the limits of High Court powers in quashing criminal proceedings under Section 482 of the Criminal Procedure Code (Cr.P.C.). The Supreme Court overturned the Punjab and Haryana High Court’s decision, which had quashed FIR No. RC0512020S0001, directing that the accused face trial.

The case dates back to an FIR registered in 2014, later transferred to the CBI in 2020 for further investigation. The trial court had refused to discharge the accused, but the High Court quashed the proceedings. The Supreme Court ruled that the High Court overstepped its jurisdiction, emphasizing that charges must be tested through trial.

Background of the Case

The original FIR was registered in 2014 at Police Station Phase-1, Mohali, under various sections of the IPC, including Sections 452 (house trespass), 323 (voluntarily causing hurt), 365 (kidnapping), 342 (wrongful confinement), 186 (obstructing public servant), 225 (resistance to lawful custody), 506 (criminal intimidation), and 120-B (criminal conspiracy). The case was later transferred to the Crime Branch, Chandigarh, where it was re-registered as FIR No. RC0512020S0001 on April 29, 2020.

Initially, the accused Aryan Singh was not named in the fresh FIR, but after an investigation, a charge sheet was filed against him, along with co-accused Gautam Cheema. Both accused sought discharge from the trial court, which was denied. They then approached the High Court, which quashed the criminal proceedings, leading to the CBI’s appeal in the Supreme Court.

Arguments by the Parties

CBI’s Submissions

The Additional Solicitor General (ASG), appearing for the CBI, made the following points:

The High Court exceeded its jurisdiction under Section 482 Cr.P.C. by quashing the proceedings, as if conducting a mini-trial.
The High Court wrongly observed that the allegations were unproven and that the prosecution was malicious, despite the case being transferred to the CBI by court order.
It was improper for the High Court to decide whether the charges were valid without trial. The validity of charges should be determined during trial based on evidence.
The trial court had rightly refused discharge, as there was sufficient material to proceed against the accused.

Defense Submissions

The defense, led by senior counsels for Aryan Singh and Gautam Cheema, argued:

The allegations against the accused lacked merit and were an abuse of the legal process.
The CBI’s charge sheet did not provide substantial evidence to justify the trial.
The prosecution was politically motivated and amounted to harassment of the accused.
The High Court was justified in exercising its inherent power to quash frivolous criminal proceedings.

Supreme Court’s Observations and Ruling

The Supreme Court, comprising Justices M.R. Shah and C.T. Ravikumar, found that the High Court had overstepped its jurisdiction by analyzing the merits of the case at the pre-trial stage.

The Court emphasized:

The High Court had acted beyond its authority by determining that the charges were unproven before trial.
The standard for quashing proceedings under Section 482 Cr.P.C. is whether there is sufficient material for trial, not whether the prosecution has already proven its case.
Whether the proceedings were malicious could only be determined at the conclusion of the trial, not during pre-trial proceedings.
The High Court had effectively conducted a mini-trial, which is against established legal principles.

Final Judgment

The Supreme Court set aside the High Court’s judgment and restored the criminal proceedings against the accused. It directed the trial court to conclude the case within 12 months and instructed all parties to cooperate with the proceedings.

Judges: M.R. Shah and C.T. Ravikumar

Judgment Date: April 10, 2023

Petitioner Name: Central Bureau of Investigation.
Respondent Name: Aryan Singh.
Judgment By: Justice M.R. Shah, Justice C.T. Ravikumar.
Place Of Incident: Mohali, Punjab.
Judgment Date: 10-04-2023.

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