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Supreme Court of India 2025-11-20 allowed

Robert Lalchungnunga Chongthu @ R. L. Chongthu vs State of Bihar

Bench: 2 — Sanjay Karol, Nongmeikapam Kotiswar Singh

In Brief

An IAS officer serving as District Magistrate issued arms licences without full police verification, citing discretion under the Arms Act. After an initial clearance in 2006, investigation resumed in 2009 and a supplementary chargesheet was filed in 2020—11 years later. The prosecution was sanctioned in 2022. The Supreme Court allowed the appeal, holding that the 11-year investigative delay violated the right to speedy trial under Article 21, and the sanction order was invalid because it mechanically approved prosecution without showing the sanctioning authority's reasoned application of mind. Once the sanction was void, cognizance and all criminal proceedings were quashed. The Court emphasized that investigations cannot continue indefinitely without justification.

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Criminal Procedure Arms Act Right to Speedy Trial Article 21 Sanction for Prosecution of Public Servants Investigation Delays Discretionary Powers Administrative Law Constitutional Law

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