Quashing of Criminal Proceedings – No Vicarious Liability Without Statutory Provision – The Supreme Court quashed criminal proceedings initiated against company directors for alleged violation of Section 4 of the Punjab Land Preservation Act, 1900, punishable under Section 19 of the said Act. It held that there was no provision imposing vicarious liability on company directors for environmental violations in the absence of specific allegations against them. (Paras 10-14)

Corporate Liability – Distinction Between Company and Individual Accountability – The Court emphasized that a company may be held liable for environmental violations, but its directors can only be held responsible if there is a statutory provision or specific allegations proving their direct involvement. Mere position in the company does not attract criminal liability. (Paras 11-12)

Criminal Jurisprudence – Requirement of Specific Allegations for Prosecution – The Court reiterated the principle that criminal liability cannot be automatically fastened upon officers of a company unless the statute specifically provides for it. In this case, there were no allegations linking the directors personally to the offence. (Paras 13-15)

Abuse of Process – Duty of Courts to Apply Mind Before Issuing Process – The Supreme Court criticized the lower courts for failing to assess whether the allegations, even if taken at face value, constituted an offence against the directors. It reaffirmed that judicial discretion must be exercised before issuing summons in criminal complaints. (Para 16)

Acts and Sections Discussed:

• Constitution of India – Article 21 (Right to Life and Liberty)
• Code of Criminal Procedure, 1973 – Section 482 (Inherent Powers of the High Court)
• Indian Penal Code, 1860 – Section 34 (Common Intention)
• Punjab Land Preservation Act, 1900 – Section 4 (Prohibition of Unauthorized Clearing of Land), Section 19 (Penalty for Offences)

Subjects:

Vicarious Liability – Corporate Liability – Environmental Law – Criminal Prosecution – Section 482 CrPC – Quashing FIR – Judicial Review – Punjab Land Preservation Act