The Supreme Court upheld the High Court’s order quashing criminal proceedings, emphasizing that the FIR and complaint failed to disclose a cognizable offense against the accused. The Court found the allegations vague, unsubstantiated, and lacking any material to connect the accused to the crime, making the case unsustainable.
Facts Of The Case:
The case originated from a written complaint dated May 28, 2015, by a Member of the Legislative Assembly (MLA) to the Anti-Corruption Bureau in Hyderabad. He alleged that the fourth accused (A4), Jerusalem Mathai, had offered him Rs. 2 crores and a ticket to leave the country to abstain from voting in the upcoming Member of Legislative Council (MLC) elections. A subsequent paragraph in the same complaint mentioned a higher offer of Rs. 5 crores from another individual for the same purpose, but this allegation was not linked to A4. No First Information Report (FIR) was registered immediately on this complaint. Instead, an FIR was registered on May 31, 2015, based on a police operation at a friend’s residence of the complainant, where individuals related to the second offer were allegedly caught. Audio and video recordings were made, and a case was registered under the Prevention of Corruption Act, 1988. Crucially, A4 was not present during this alleged transaction on May 31. The State challenged the High Court’s decision to quash the proceedings against A4, arguing it conducted a “mini-trial,” while the accused contended there was no credible material connecting him to the crime.
Procedural History:
The procedural history of this case began with the registration of a First Information Report (FIR) by the Anti-Corruption Bureau against multiple accused, including the respondent Jerusalem Mathai (A4), under the Prevention of Corruption Act, 1988. Following this, A4 approached the High Court, filing a petition to quash the FIR and the subsequent criminal proceedings initiated against him. The High Court, after examining the material on record, allowed the petition and quashed the proceedings specifically concerning A4. Aggrieved by this decision, the State of Telangana filed a Special Leave Petition before the Supreme Court of India, challenging the legality of the High Court’s order. The Supreme Court, after hearing the arguments, dismissed the State’s petition, thereby upholding the High Court’s judgment and finally concluding the case against A4.
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Court Observation:
The Supreme Court made key observations on both procedural and substantive aspects. It first addressed the State’s allegation that the High Court had conducted a “mini-trial,” clarifying that while the High Court’s order was lengthy, this alone did not invalidate it, as the reasoning for quashing was justifiable. On the substantive issue, the Court focused on the allegations against A4 (Jerusalem Mathai) and found them severely deficient. It noted that the initial written complaint contained a vague and isolated allegation against A4, with no details on the timing of the alleged offer or the complainant’s response. Crucially, the Court emphasized that A4 was not present during the police operation on May 31, 2015, where the alleged bribe transaction occurred, and the complaint failed to link him to the other accused or the specific criminal event. Ultimately, the Court concluded that the FIR and complaint disclosed no cognizable offense against A4, as there was absolutely no material to connect him to the crime.
Final Decision & Judgement:
The Supreme Court dismissed the Special Leave Petitions filed by the State of Telangana and upheld the High Court’s order quashing the criminal proceedings against the respondent, Jerusalem Mathai (A4). The Court concluded that there was no error in the High Court’s decision, as the First Information Report (FIR) and the complaint failed to disclose any cognizable offense against A4. It found no credible material to connect him to the alleged crime, noting his absence from the scene of the transaction and the vague, unsubstantiated nature of the accusations. The dismissal of the appeals brought a final end to the criminal case against A4.
Case Details:
Case Title: The State of Telangana vs. Jerusalem Mathai and Anr. CITATION: Special Leave Petition (Crl.) No. 5248 of 2016 Date Of Judgement: September 26, 2025 Judges/Justice Name: Justice B.R. Gavai & Justice K. Vinod Chandran
Download The Judgement Here