Criminal proceedings by themselves cannot become a punishment, the Supreme Court asserted, cautioning trial courts against allowing trials in the absence of a prima facie case.
Prosecution cannot be allowed in absence of prima facie case: SCInsisting that judges must carefully scrutinize the material before framing a charge, a bench of Justices Sanjay Karol and N Koteshwar Singh said allowing a case to proceed without a legal basis exposes an accused to “unnecessary stress, stigma and uncertainty of criminal procedure”.
“Faithfulness to the rule of law requires the court to bear in mind that the process itself can become a punishment if this duty is not carefully exercised,” the bench held in its judgment, which was made available on Wednesday.
The Court emphasized that at the stage of framing or considering disposition of disciplinary charges, judges are not engaged in an abstract legal exercise but are dealing with “real people, real concerns and the real weight of criminal justice.”
The power to frame charges, it said, is not meant to be used by default or as a matter of mere precaution. If the material on record, taken at face value, does not reveal the elements of the offence, the court is expected to have the “clarity and courage” to acquit the accused.
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“Discharge, in that sense, is not a technical indulgence but an essential safeguard. Courts must distinguish between a genuine case which warrants a trial and one which rests only on suspicion or conjecture or without any basis for that matter,” it asserted.
The bench, in its judgment, also underlined that trial courts, often the first point of contact for litigants, bear the “heaviest” responsibility to carefully distinguish between genuine cases and genuine cases resting on mere suspicion.
“For a litigant or an accused, the court of justice is not just a level in a hierarchy. It represents the face of the judiciary itself. The sensitivity, fairness and legal discipline displayed at this level shape how ordinary citizens understand justice. The impression a court of law creates, through its approach to facts and the law, often does not become the impression of the entire judiciary, “not a human concept.
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That is why, the apex court added, at every stage and especially at the threshold, the courts must be alive to the human consequences of their decisions and the trust that society reposes in them.
The observations came as the bench on Tuesday quashed criminal proceedings against Madhya Pradesh’s Vyapam scam whistleblower Anand Rai as they related to offenses under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.
The bench held that the material on record did not disclose the elements required to attract offenses under the SC/ST Act. It noted that the trial court itself admitted that the statement recorded during the investigation did not contain specific race-based slurs or allegations showing intent to insult or intimidate on the basis of caste.
The bench found error in the Madhya Pradesh High Court’s July 2025 order upholding the formulation of the complaint, noting that it had not independently examined the applicability of the provisions of the SC/ST Act.
While quashing the charges under the SC/ST Act, the court referred the matter back to the trial court for proceeding under the rest of the Indian Penal Code. It clarified that its findings were limited to grievances under the SC/ST Act.
In its judgment, the court also reflected on the significance of the SC/ST Act as a transformative law aimed at addressing historical discrimination, untouchability and caste-based violence and realizing constitutional guarantees of equality, dignity and social justice. However, it emphasized that even such protective legislation should be introduced only when statutory requirements are met.
Rai, a doctor known for exposing irregularities in medical admissions in the Byapam scam, had challenged the framing of charges against him over a 2022 incident during a public event in Madhya Pradesh. The Supreme Court had earlier adjourned the trial to July 2025.
