The Supreme Court quashed the criminal proceedings, applying the Bhajan Lal principles. It held that the allegations, even if accepted entirely, did not prima facie constitute the offences under Sections 290, 341, 171F IPC, and Section 34 of the Police Act, 1861, as their essential ingredients were absent. Continuing the prosecution was deemed an abuse of the process of law.
Facts Of The Case:
During the 2019 General Elections, the Model Code of Conduct was in force in Andhra Pradesh. On March 22, 2019, appellants Manchu Mohan Babu, an educational institution chairman, and his son, along with staff and students, conducted a rally and dharna on the Tirupati-Madanapalli Road. They were protesting the state government’s failure to provide student fee reimbursements. The gathering, which lasted from 8:30 AM to 12:30 PM, was alleged to have obstructed traffic and caused public inconvenience. A complaint was filed by a Model Code of Conduct official, leading to the registration of FIR No. 102 of 2019 at Chandragiri Police Station. The appellants were charged under Sections 290 (Public Nuisance), 341 (Wrongful Restraint), and 171F (Undue Influence at Elections) read with Section 34 (Common Intention) of the Indian Penal Code, and Section 34 of the Police Act, 1861. After a chargesheet was filed, the appellants approached the High Court to quash the proceedings, which was refused, leading them to appeal to the Supreme Court.
Procedural History:
The procedural history of the case began with the registration of FIR No. 102 of 2019 on March 22, 2019, at Chandragiri Police Station against the appellants. Following an investigation, the police filed a chargesheet on June 3, 2020, in C.C. No. 1015 of 2021 before the Court of the IV Additional Junior Civil Judge, Tirupati. Aggrieved by the initiation of these criminal proceedings, the appellants filed a petition under Section 482 of the Cr.P.C. before the High Court of Andhra Pradesh at Amaravati, registered as Criminal Petition No. 7446 of 2022, seeking to quash the proceedings. The High Court, vide its impugned judgment dated January 2, 2025, dismissed the petition, concluding that the allegations disclosed prima facie offences and provided no tenable grounds for quashing. This dismissal prompted the appellants to file Special Leave Petitions before the Supreme Court, which granted leave and culminated in the present appeals.
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Court Observation:
In its observations, the Supreme Court meticulously applied the principles laid down in State of Haryana v. Bhajan Lal to determine if the allegations, even if taken at face value, constituted a cognizable offence. The Court found that the essential ingredients of the alleged offences under Sections 290, 341, and 171F of the IPC were entirely absent from the FIR and chargesheet. It observed that the appellants’ actions constituted a peaceful exercise of their fundamental rights to speech and assembly, and did not amount to public nuisance, wrongful restraint, or undue influence in elections as defined by law. Furthermore, the acts described did not fall within any of the specific categories of offences listed under Section 34 of the Police Act, 1861. The Court concluded that allowing the prosecution to continue would be an abuse of the process of law, as no prima facie case was made out and the chances of an ultimate conviction were non-existent.
Final Decision & Judgement:
The Supreme Court allowed the appeals and set aside the impugned judgment of the High Court. The Court exercised its powers under Article 136 of the Constitution and Section 482 of the Cr.P.C. to quash the criminal proceedings, holding that continuing the prosecution would be an abuse of the process of law. Consequently, FIR No. 102 of 2019 registered at Chandragiri Police Station and all ensuing proceedings in C.C. No. 1015 of 2021 before the IV Additional Junior Civil Judge, Tirupati, were unequivocally quashed. The Bench ruled that the allegations, even accepted in their entirety, failed to prima facie constitute any of the offences charged, thereby securing the appellants from further legal action.
Case Details:
Case Title: Manchu Mohan Babu & Anr. vs. State of Andhra Pradesh & Anr. Citation: 2025 INSC 916 Criminal Appeal No.: Criminal Appeal No. 3298 of 2025 Date of Judgement: July 31, 2025 Judges/Justice Name: Justice B.V. Nagarathna and Justice K.V. Viswanathan
Download The Judgement Here