Supreme Court Quashes Criminal Proceedings Based on CCTV Evidence; Holds Vague Allegations and Mala Fides Justify Intervention Under Section 482 CrPC

Case Name: Sajal Bose v. State of West Bengal and Others
Citation: 2026 INSC 322
Date of Judgment/Order: 06 April 2026
Bench: Hon’ble Mr. Justice Vikram Nath; Hon’ble Mr. Justice Sandeep Mehta; Hon’ble Mr. Justice N. V. Anjaria

Held: The Supreme Court held that criminal proceedings can be quashed at the threshold where allegations are vague, lack specific attribution of overt acts, and are contradicted by unimpeachable evidence such as CCTV footage, and reiterated that continuation of such proceedings would amount to abuse of process under the principles laid down in Bhajan Lal.

Summary: The case arose from an FIR alleging assault and criminal intimidation in a residential dispute, where multiple accused persons were chargesheeted under various IPC provisions. The High Court partially quashed proceedings against some co-accused but allowed trial to continue against the appellants. Before the Supreme Court, the appellants contended that the allegations were omnibus, mala fide, and unsupported by material evidence, particularly in light of CCTV footage forming part of the chargesheet. The Court examined the FIR, witness statements, and electronic evidence, and found that the allegations against the appellants were vague and lacked specific attribution of acts. Crucially, the CCTV footage demonstrated that the appellants were not present during the alleged assault and had arrived later, appearing to pacify the situation rather than participate in any offence. The Court held that such unimpeachable evidence materially undermines the prosecution case even at the stage of quashing. It further observed that the High Court failed to consider this crucial evidence and also erred in granting differential treatment to similarly placed co-accused without cogent reasoning. Applying the principles laid down in State of Haryana v. Bhajan Lal and the four-step test in Pradeep Kumar Kesarwani, the Court concluded that the case fell within categories warranting quashing, including absence of prima facie offence, lack of supporting material, and mala fide prosecution.

Decision: The Supreme Court allowed the appeals, set aside the High Court judgment insofar as it refused to quash proceedings against the appellants, and quashed Charge Sheet No. 135 of 2022 and all consequential proceedings arising out of FIR No. 150 of 2022 insofar as they related to the appellants, with all pending applications disposed of accordingly.