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Supreme Court of India 2018-09-13 allowed

Abdul Wahab K vs State of Kerala and Others

Bench: 2 — Dipak Misra

In Brief

A trial court permitted the Public Prosecutor to withdraw from a criminal prosecution (under IPC Sections 506 and 195A) based on a government notification, without substantive judicial scrutiny. The appellant, a third party, challenged this in revision petitions, but the High Court dismissed them on grounds that the revising petitioner was a stranger to the case. The Supreme Court held that while courts need not conduct a detailed factual enquiry into withdrawal applications, they must exercise informed, independent judicial discretion to ensure the withdrawal serves justice, not merely the Government's or prosecutor's convenience. The Public Prosecutor must apply independent mind and the trial judge must verify that withdrawal is in good faith and advances public interest. The Court set aside both orders and remitted the matter for fresh consideration.

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Criminal Procedure Public Prosecution Discretionary Powers of Court Withdrawal of Prosecution Administrative Law Public Interest Litigation

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