The Supreme Court allowed the appellant’s discharge, holding that the deaths resulted from a forest fire (vis major) and no criminal negligence or intent was attributable to him. Consequently, the invocation of Sections 304 (Part II), 304A, 326, and 338 of the Indian Penal Code was found to be unwarranted on the facts of the case.
Facts Of The Case:
The case arose from a tragic 2018 forest fire in Kurangani, Tamil Nadu, which caused multiple fatalities and injuries during a trekking expedition. The appellant, a Forester, was accused No. 1. The prosecution alleged that he, while entrusted with additional charge of the Mandal Division, facilitated a trekking group from Erode by instructing a local watcher to accompany them. It was further alleged that trekking fees were paid into his personal account and that the group, with his knowledge, was guided through a prohibited forest area, exposing them to the foreseeable risk of fire. The investigation led to charges under Sections 304 (Part II), 304A, 326, and 338 of the IPC. While the proceedings against accused No. 3 (the trek organizer) were quashed by the Supreme Court in a prior order, the appellant’s discharge petitions were dismissed by the trial court and the High Court, which held there was sufficient material to proceed against him, distinguishing his more serious alleged role.
Procedural History:
The procedural history began with the registration of FIR No. 18 of 2018. After investigation, a chargesheet was filed, and the case was committed to the Sessions Court as S.C. No. 70 of 2019. The appellant’s discharge petition (M.P. No. 1 of 2024) was dismissed by the trial court. His subsequent revision petition (Crl. R.C. (MD) No. 1286 of 2024) was also dismissed by the High Court vide order dated 03.06.2025. The appellant then appealed to the Supreme Court by way of Special Leave Petition, which granted leave and culminated in the present judgment allowing the appeal and discharging the appellant.
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Court Observation:
The Supreme Court observed that the tragic incident was caused by a forest fire, an instance of vis major (act of God), and no criminal negligence or intent could be attributed to the appellant-forester for the deaths. The Court found that the essential ingredients for offences under Sections 304 (Part II), 304A, 326, and 338 of the Indian Penal Code were not met, as there was no knowledge or intention to cause death or grievous hurt, and the deaths resulted solely from a natural calamity. Applying its prior reasoning from a co-accused’s case, the Court held that merely facilitating the trek as a forest official did not attract criminal liability, and the lower courts erred in not discharging the appellant.
Final Decision & Judgement:
The Supreme Court allowed the appeal, set aside the orders of the High Court and the Sessions Court, and discharged the appellant from all offences alleged under Sections 304 (Part II), 304A, 326, and 338 of the Indian Penal Code. The Court held that the criminal proceedings against him were unsustainable as the deaths were caused by a forest fire (vis major) and no element of criminal negligence or intent was established.
Case Details:
Case Title: Jeyasingh vs. The State Rep. by the Inspector of Police, Tamil Nadu Citation: 2025 INSC 1422 Criminal Appeal No.: (Arising from SLP(Crl.) No(s). 14226/2025) Date of Judgement: NOVEMBER 18, 2025 Judges/Justice Name: Justice B.V. Nagarathna and Justice R. Mahadevan
Download The Judgement Here