2012 (8) TMI 914 - SC - Indian Laws

Exoneration in Departmental Proceeding /= Acquittal in Criminal Trial: Supreme Court Clarifies

The Supreme Court held that exoneration in a departmental proceeding does not automatically lead to the quashing of criminal prosecution. The Court ... Whether the prosecution against an accused, notwithstanding his exoneration on the identical charge in the departmental proceeding could continue or not? Whether exoneration in the departmental proceeding ipso facto would not result into the quashing of the criminal prosecution? Issues Involved:1. Whether exoneration in a departmental proceeding can lead to the quashing of criminal prosecution on the same charges.2. The validity of the High Court's decision to quash the criminal proceedings based on the departmental exoneration.3. The standard of proof required in departmental proceedings versus criminal trials.4. The impact of conflicting judgments on the same legal issue.Issue-wise Detailed Analysis:1. Whether exoneration in a departmental proceeding can lead to the quashing of criminal prosecution on the same charges:The Supreme Court examined whether an exoneration in a departmental proceeding automatically results in the quashing of a criminal prosecution. The Court emphasized that the standard of proof in departmental proceedings is lower than in criminal trials. Departmental proceedings are usually conducted by officers who may not be legally trained, whereas criminal trials are conducted by judges trained in law. The Court held that exoneration in a departmental proceeding does not ipso facto lead to the termination of criminal prosecution. This principle was reaffirmed by referencing previous judgments, including 'State v. M. Krishna Mohan' and 'Supdt. of Police (C.B.I.) v. Deepak Chowdhary,' which supported the view that departmental exoneration does not automatically lead to acquittal in criminal trials.2. The validity of the High Court's decision to quash the criminal proceedings based on the departmental exoneration:The Supreme Court found that the High Court erred in quashing the criminal proceedings on the premise that the accused had been exonerated in the departmental proceeding. The High Court's decision was based on an erroneous assumption that the inquiry officer's report, which found the allegations unsubstantiated, equated to the exoneration of the accused. The Supreme Court clarified that the disciplinary authority is not bound by the inquiry officer's conclusions and can disagree with the findings after following due process. Therefore, the High Court's order was set aside as it was founded on an incorrect premise.3. The standard of proof required in departmental proceedings versus criminal trials:The Supreme Court reiterated that the standard of proof in departmental proceedings is lower compared to criminal trials. Criminal trials require proof beyond a reasonable doubt, whereas departmental proceedings require a preponderance of probabilities. The Court emphasized that the truthfulness of evidence in a criminal case can only be judged after evidence is adduced in the trial. Therefore, the outcome of departmental proceedings cannot be the sole basis for quashing criminal prosecution.4. The impact of conflicting judgments on the same legal issue:The Supreme Court addressed the conflicting judgments regarding the impact of departmental exoneration on criminal prosecution. The Court referred to two conflicting judgments: 'P.S. Rajya vs. State of Bihar' and 'Kishan Singh Through Lrs. Vs. Gurpal Singh & Others.' The Court clarified that 'P.S. Rajya' did not establish a general rule that exoneration in departmental proceedings automatically leads to the quashing of criminal prosecution. Instead, it was based on the peculiar facts of that case. The Court affirmed the view that criminal prosecution can continue independently of departmental proceedings and emphasized that each case must be judged on its own facts and merits.Conclusion:The Supreme Court concluded that the High Court's order quashing the criminal proceedings was unsustainable both on facts and law. The accused was directed to appear before the trial court, and the trial court was instructed to expedite the proceedings. The appeal was allowed, and the High Court's order was set aside. The Supreme Court's judgment clarified that exoneration in departmental proceedings does not automatically result in the termination of criminal prosecution and reaffirmed the distinct standards of proof required in departmental and criminal proceedings.