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Supreme Court of India 2021-11-29 dismissed

Pradeep S. Wodeyar vs The State of Karnataka

Bench: 3 — Dhananjaya Y Chandrachud, Vikram Nath, B V Nagarathna

In Brief

The Supreme Court upheld the criminal prosecution of company executives for illegal mining and export of iron ore despite procedural irregularities. Although the Special Court lacked inherent power to take cognizance without magistrate committal under the Criminal Procedure Code, the Court held the irregularity did not vitiate proceedings because: (1) Section 465 CrPC permits overlooking procedural irregularities if no failure of justice occurs; (2) the challenge was delayed two years, when it should have been raised immediately; and (3) cognizance based on a police investigation report does not require elaborate reasoning. The Court also held the Special Court can jointly try related offences under the MMDR Act and IPC without implied repeal, and vicarious liability of managing directors remains a trial matter.",

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Criminal Procedure Jurisdiction of Courts Special Courts Cognizance of Offences Environmental Law Illegal Mining Vicarious Liability Joint Trial Section 465 CrPC Irregularity in Proceedings Application of Mind

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