Three appellants — Sajal Bose, Chandidas Joardar, and Sautrik Joardar — challenged the Calcutta High Court's refusal to quash a chargesheet (Chargesheet No. 135 of 2022) arising out of FIR No. 150 of 2022 registered at Police Station Survey Park, under Sections 143, 341, 323, 324, 504, 506, 509, 427 and 354 IPC. The FIR stemmed from an alleged assault and criminal intimidation during a neighbour dispute at a Kolkata apartment complex on the night of 11 October 2022. By the same impugned order dated 8 March 2024, the High Court had quashed proceedings against two co-accused (the wives of appellant Nos. 1 and 2) but declined similar relief to the three appellants, permitting their trial to continue before the Additional Chief Judicial Magistrate, South 24 Parganas at Alipore.
The Supreme Court, on Criminal Appeals Nos. 1774–1776 of 2026, allowed all three appeals and quashed the chargesheet qua the appellants. The Court itself viewed the CCTV footage forming part of the prosecution's own chargesheet and found that the appellants were not present at the scene during the actual altercation; they arrived later and appeared to be pacifying the parties rather than participating in any assault. The Court held that this unimpeachable electronic evidence completely belied the allegations, that the FIR attributed no specific overt act of physical assault to the appellants, and that the pre-existing disputes between the parties lent credence to the claim of malafide prosecution.
The Court applied the seven-category framework from State of Haryana v. Bhajan Lal [1990] Supp. 3 SCR 259 and the structured four-step test recently articulated in Pradeep Kumar Kesarwani v. State of Uttar Pradesh, 2025 SCC OnLine SC 1947, finding the case fell within categories (1), (3) and (7) of Bhajan Lal. It further criticised the High Court for granting relief to similarly placed co-accused without extending parity to the appellants and for failing to meaningfully analyse the CCTV footage despite it being central to both sides' arguments.