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Supreme Court of India 2024-02-16 allowed

N. MANOGAR & ANR vs THE INSPECTOR OF POLICE & ORS

Bench: 2 — Vikram Nath, Satish Chandra Sharma

In Brief

The Supreme Court reversed a High Court order that had impleaded two additional persons as accused in a criminal case involving charges of house trespass, assault, and threatening language. The High Court had relied on vague allegations and investigative statements to exercise its discretionary power under Section 319 of the Criminal Procedure Code. The Supreme Court held that this power must be exercised sparingly and requires evidence showing near-certainty of involvement—stronger than a prima facie case but not requiring proof beyond doubt. Here, the materials did not meet that threshold. The Trial Court's reasoned refusal to implead the Appellants was upheld, and the High Court's decision was set aside.

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Criminal Procedure Impleadment of Accused Section 319 CrPC Discretionary Powers Criminal Investigation Evidence

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