The Court Held That the Criminal Proceedings Were Manifestly Attended With Mala Fide and Instituted With Ulterior Motive – No Sufficient Evidence to Sustain the Charges – Quashing the FIR Secured the Ends of Justice

(a) The allegations in the FIR, even if taken at face value, did not disclose any offence. (b) The absence of the required sanction under Section 196(1A) CrPC created a legal bar against proceeding with the case. (c) The criminal proceedings were manifestly attended with mala fide and instituted with an ulterior motive. (Para 6, Para 7, Para 9, Para 10, Para 13)

The Court quashed the FIR and the criminal proceedings, noting the absence of a prima facie case and the failure to obtain mandatory sanction under Section 196(1A) of the CrPC.

Acts and Sections Discussed:

1. Constitution of India (COI) – Article 226

2. Code of Criminal Procedure, 1973 (CrPC) – Section 482, Section 196(1A)

3. Indian Penal Code, 1860 (IPC) – Section 298, Section 505, Section 505(2), Section 506, Section 507

4. Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (Atrocities Act) – Section 3(1)(u), Section 3(1)(v)

Subjects: FIR Quashing – Prima Facie Case – Legal Bar – Absence of Sanction – Mala Fide Prosecution – Abuse of Process – Ends of Justice

Nature of the Litigation: The criminal application was filed to quash the FIR registered as Crime No.89/2019 and the proceedings in Special Case No.52/2020 pending before the Special Judge under the Atrocities Act.

Who Asked the Court and for What Remedy: The applicant, Devendra Rajiv Patil, requested the Court to quash the FIR and the related criminal proceedings, arguing that the allegations did not disclose any prima facie case and were attended with mala fide.

Reason for Filing the Case: The FIR alleged that the applicant made derogatory remarks against a late leader held in high esteem by the Scheduled Caste community, which the applicant denied. The case was filed based on a telephonic conversation and social media posts.

What Had Already Been Decided Until Now: The charge sheet was filed without proper evidence, including the absence of voice analysis reports and call detail records. The Court noted the lack of prior sanction required under Section 196(1A) of the CrPC.

Issues:

1. Whether the FIR and criminal proceedings disclosed a prima facie case against the applicant.

2. Whether the absence of sanction under Section 196(1A) of the CrPC rendered the proceedings void.

3. Whether the allegations in the FIR constituted an abuse of the court process.

Submissions/Arguments:

(a) The applicant contended that the FIR was filed with a mala fide intention and lacked evidence. (b) The prosecution argued there was sufficient evidence linking the applicant to the alleged offence, including statements of witnesses and a purported confession.