The Supreme Court on 6 April 2026 allowed the appeals filed by Sajal Bose, Chandidas Joardar and Sautrik Joardar and quashed the criminal proceedings against them arising out of FIR No. 150 of 2022 registered at Police Station Survey Park, Kolkata. Justices Vikram Nath, Sandeep Mehta and NV Anjaria held that where reliable and unimpeachable material, such as CCTV footage forming part of the charge sheet, 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 under Section 482 CrPC to prevent injustice.
The case arose from an alleged altercation on the night of 11 October 2022 at an apartment complex in Kolkata. The complainant, a 77-year-old former Public Prosecutor, alleged that the appellants and others formed an unlawful assembly, abused and assaulted him and his family members, and issued threats. The FIR invoked Sections 143, 341, 323, 324, 504, 506, 509, 427 and 354 IPC. After investigation, a charge sheet was filed. While the Calcutta High Court quashed the proceedings against two co-accused (Nabina Bose and Pampa Joardar) for want of specific allegations, it declined similar relief to the present appellants.
Assailing the High Court’s order, the appellants contended before the Supreme Court that the allegations were vague, omnibus and actuated by mala fide arising out of prior civil disputes between the parties. They heavily relied upon the CCTV footage collected during investigation, which formed part of the charge sheet. The footage, according to them, showed that they arrived at the scene only after the altercation had already taken place and made efforts to pacify the situation rather than participating in any act of violence.
The Supreme Court, after carefully viewing the CCTV footage, observed that it materially undermines the prosecution’s case. The recording did not depict the appellants committing any overt act of assault or aggression. On the contrary, it showed them attempting to restrain and de-escalate the situation. The Court noted that the High Court failed to independently examine this crucial piece of electronic evidence while declining to quash the proceedings against the appellants.
Referring to the four-step test laid down in Pradeep Kumar Kesarwani v. State of Uttar Pradesh (2025 LiveLaw (SC) 880), the Court held that the material relied upon by the appellants is of sterling and impeccable quality, is sufficient to negate the allegations, remains unrefuted by the prosecution, and that continuation of the proceedings would amount to an abuse of the process of law. The Court further observed that the allegations in the FIR were general in nature and did not attribute specific overt acts to the individual appellants so as to justify their being put to trial.
Accordingly, the Supreme Court set aside the impugned judgment of the Calcutta High Court to the extent it refused to quash the proceedings against the appellants and quashed the charge sheet and the criminal proceedings qua them. The appeals were allowed.
Case Title: Sajal Bose v. The State of West Bengal and Ors.
Case No.: Criminal Appeal Nos. of 2026 (arising out of SLP(Criminal) Nos. 8672, 8721 and 9826 of 2024)
Date of Judgment: 6 April 2026
Coram: Hon’ble Mr. Justice Vikram Nath, Hon’ble Mr. Justice Sandeep Mehta and Hon’ble Mr. Justice NV Anjaria
Click HERE for full Judgment.
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