Suspecting Citizen After Honourable Acquittal Militates Rule Of Law: Allahabad HC

🔹 Core Principle

Rule of Law demands that once a court of law acquits an accused, especially by granting an honourable acquittal, the presumption of innocence is reaffirmed.

Continuing to suspect, stigmatize, or deny rights to such a person would amount to a serious violation of constitutional guarantees under Articles 14, 19, and 21.

🔹 What is “Honourable Acquittal”?

An honourable acquittal occurs when:

The court finds that the prosecution has miserably failed to prove charges.

The accused is fully exonerated on merits, not merely acquitted on benefit of doubt or technical grounds.

It restores the dignity and rights of the accused in the eyes of law and society.

🔹 Judicial Reasoning of Allahabad HC

Presumption of innocence strengthened → Acquittal restores the fundamental right to live with dignity.

State authorities bound → Police or administration cannot continue to treat the acquitted person as a suspect or deny him employment, passport, service benefits, etc.

Militates against Rule of Law → To keep suspecting a citizen even after judicial exoneration undermines faith in courts, violates fairness, and erodes public trust.

Right to reputation → Part of Article 21 (as held in State of Bihar v. Lal Krishna Advani, Kiran Bedi v. Committee of Inquiry).

🔹 Important Case Laws

1. State of Rajasthan v. Madan Lal (2015) 11 SCC 496

SC held that after acquittal, stigma cannot continue; presumption of innocence is reinforced.

2. R.P. Kapur v. Union of India (1964) AIR SC 787

Once honourably acquitted, it would be unjust to continue departmental proceedings on the same charges unless there is independent evidence of misconduct.

3. Deputy Inspector General of Police v. S. Samuthiram (2013) 1 SCC 598

Distinguished between honourable acquittal and acquittal on benefit of doubt; held that only an honourable acquittal completely wipes out stigma.

4. Union Territory, Chandigarh v. Pradeep Kumar (2018) 1 SCC 797

SC emphasized that after honourable acquittal, the person cannot be denied public employment merely on past suspicion.

5. Allahabad HC (Recent Observations)

The Court stressed that suspecting a citizen post-acquittal undermines Rule of Law and violates the constitutional right to dignity and liberty.

🔹 Why It Militates Against Rule of Law

Rule of Law = No one above law, no one punished without legal basis.

Once acquitted, there is no legal basis to suspect/penalize.

To continue suspicion = amounts to extra-judicial punishment, contrary to constitutional governance.

✅ Conclusion

The Allahabad HC rightly held that after an honourable acquittal, suspicion cannot linger.

The accused is to be treated as innocent in the eyes of law.

Any further suspicion, denial of rights, or stigma would violate the Rule of Law, Article 21, and the dignity of the individual.

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