Supreme Court Quashes FIR and Chargesheet Against Appellants in Gorakhpur College Admission Fraud Case. The Supreme Court rules that the criminal proceedings against the appellants are an abuse of process due to lack of evidence linking them to the alleged offenses.


Summary of Judgement

The Supreme Court has quashed the FIR and chargesheet against the appellants, who were accused of involvement in illegal admissions at the Raj School of Nursing and Paramedical College, Gorakhpur. The Court found that the FIR did not disclose any material to support the allegations against the appellants and held that their prosecution would result in undue harassment and an abuse of process. The High Court's earlier dismissal of the petition to quash the FIR was overturned, and the continuation of the criminal proceedings was deemed unjustified.

1. Introduction

  • The appellants challenged the High Court’s order rejecting their petition to quash an FIR filed against them in connection with alleged illegal admissions at Raj School of Nursing and Paramedical College, Gorakhpur.

2. Background of the Case

  • The FIR alleged that the college initially had permission for 60 seats, which was later reduced to 40. Despite this, 60 students were admitted, leading to complaints from students who were later informed that their admissions were illegal.

3. FIR Details

  • The complainant accused the college officials, including the appellants, of inducing her to pay a substantial amount under the false pretense that her admission was legitimate.

4. High Court’s Decision

  • The High Court dismissed the petition to quash the FIR, stating that the appellants could seek discharge under relevant sections of the Cr.P.C., and did not consider the defense of the accused.

5. Supreme Court’s Analysis

  • The Supreme Court observed that the FIR, even if taken at face value, did not disclose any material linking the appellants to the management of the college or the alleged illegal activities. The Court emphasized that merely being related to the college officials was not sufficient to involve them in the criminal proceedings.

6. Relevant Legal Precedents

  • The Court referred to the Bhajan Lal case, which outlined scenarios where quashing of FIRs is justified, and emphasized that the power to quash should be exercised sparingly and with caution.

7. Conclusion and Final Order

  • The Supreme Court quashed the FIR and the charge-sheet against the appellants, highlighting that continuing the criminal proceedings would lead to undue harassment and an abuse of the legal process. The High Court's order was set aside, and the appellants were discharged from the case.

8. Impact of the Judgment

  • This ruling reinforces the principle that criminal proceedings should not be allowed to continue when there is no prima facie case against the accused, especially when it could lead to harassment and misuse of the legal process.

The Judgement

Case Title: MANEESHA YADAV AND OTHERS VERSUS THE STATE OF UTTAR PRADESH AND ANOTHER

Citation: 2024 LawText (SC) (4) 95

Case Number: CRIMINAL APPEAL NO. OF 2024 [Arising out of SLP(Criminal) No. 8922 of 2022] WITH CRIMINAL APPEAL NO. OF 2024 [Arising out of SLP(Criminal) No. 3698 of 2023]

Date of Decision: 2024-04-09