Ram Prakash Chadha vs. State of Uttar Pradesh [July 15, 2024]
Citation: 2024 INSC 522; Criminal Appeal No. 2395 of 2023; Supreme Court of India
Background and Facts
The case involved Ram Prakash Chadha, who sought discharge under Section 227 of the Code of Criminal Procedure (CrPC) in connection with Crime No. 371/1993, which pertained to the custodial death of Ram Kishore, his employee. The incident stemmed from Chadha’s complaint to the police regarding a theft of cash and a draft by Ram Kishore, who was then taken to the police station as a witness. Ram Kishore died in police custody, and a case was registered for custodial death, implicating Chadha and others in an alleged criminal conspiracy.
Chadha’s discharge application was rejected by the trial court, and subsequent petitions under Section 482 CrPC were dismissed by the Allahabad High Court. He appealed to the Supreme Court, challenging the sufficiency of material against him for framing charges.
Key Legal Issues
Whether the materials produced by the prosecution established a prima facie case against Chadha for criminal conspiracy in the custodial death.
The scope of the court’s power under Section 227 CrPC to discharge an accused when no sufficient ground for proceeding is found.
Supreme Court’s Analysis and Findings
The Supreme Court reiterated that at the stage of considering discharge under Section 227 CrPC, the court must only examine the record of the case and documents submitted by the prosecution, not by the accused. It cited State of Orissa v. Debendra Nath Padhi (2005) and other precedents to clarify this principle.
The Court observed that the trial court’s suspicion against Chadha was based on mere suppositions, without foundational support in the prosecution’s own materials. Notably, there was no evidence that Chadha was present at the police station or had any knowledge of Ram Kishore’s medical distress.
The trial court itself had acknowledged that in the related theft case, Ram Kishore was only a witness, and the stolen money belonged to Chadha. The Supreme Court found it illogical to implicate Chadha in a grave charge of custodial death merely because he reported the theft and brought his employee to the police station.
The Court emphasized that to attract the offence of criminal conspiracy, there must be material showing an agreement to commit a specific offence, which was absent in this case. The prosecution’s materials did not reveal any prima facie case of conspiracy or involvement of Chadha in the custodial death.
The Court criticized the High Court for failing to properly consider the lack of evidence and for upholding the trial court’s order without adequate reasoning.
Conclusion and Significance
The Supreme Court allowed the appeal, set aside the orders of the trial court and High Court, and discharged Ram Prakash Chadha from the case.
The judgment reinforces the importance of judicial scrutiny at the stage of framing charges and protects individuals from being subjected to trial based on conjecture or insufficient evidence.
It clarifies that mere suspicion or association with the complainant in a case cannot be the basis for implicating someone in serious offences like custodial death or criminal conspiracy.
In summary: The Supreme Court discharged Ram Prakash Chadha, holding that there was no prima facie material to proceed against him for custodial death or conspiracy, and emphasized that courts must base their decision to frame charges solely on the prosecution’s evidence, not on conjecture or suspicion.
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