Key Insight
SC quashes case using CCTV, reinforcing Section 482/528 to curb abuse of criminal process
Key Facts
- Supreme Court judgment dated 6 April 2026 (bench: Justices Vikram Nath, Sandeep Mehta & N.V. Anjaria).
- Case: Sajal Bose et al. v. State of West Bengal – FIR under IPC (assault, unlawful assembly, criminal intimidation).
- CCTV footage from October 2022 Kolkata apartment proved appellants were pacifying, not assaulting.
- Court invoked inherent jurisdiction under Section 482 Cr.P.C., mirrored in Section 528 BNSS, to quash proceedings.
- Applied the four‑step Kesarwani test (quality of material, negation of charge, lack of rebuttal, abuse of process).
- Lower court had only quashed two co‑accused; SC extended relief to all three appellants.
Background
The judgment underscores the Supreme Court's role in safeguarding individual liberty by preventing frivolous prosecutions, a core tenet of GS‑2 Polity. It also highlights the growing evidentiary value of technology (CCTV) and the procedural safeguards embedded in Sections 482 Cr.P.C. and 528 BNSS.
UPSC Syllabus
- Prelims_GS — Constitution and Political System
- GS2 — Executive and Judiciary - structure, organization and functioning
- GS4 — Concept of public service, philosophical basis of governance and probity
- Essay — Democracy, Governance and Public Administration
Mains Angle
GS‑2: Discuss how the judiciary balances law‑enforcement imperatives with protection of personal liberty, citing the SC's use of Section 482/528 and the Kesarwani test. Possible question: "Evaluate the role of inherent jurisdiction of courts in preventing abuse of the criminal process in India."