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Supreme Court of India 2023-05-11 dismissed

SANJAY DUBEY vs THE STATE OF MADHYA PRADESH AND ANOTHER

Bench: 2 — Krishna Murari, Ahsanuddin Amanullah

In Brief

A police inspector challenged a High Court order that, while deciding a bail application, made findings of dereliction of duty against him and directed departmental action. The Supreme Court dismissed the appeal, holding that although a bail court should ordinarily limit itself to granting or refusing bail, the High Court as a Constitutional Court may act when grave investigative lapses threaten justice delivery. However, the proper course is to direct separate proceedings under Article 226 rather than issue such directions in a bail judgment. Here, since the officer's superior had already initiated departmental enquiry, the High Court's direction was merely reiterative. The Court clarified that High Court observations shall not prejudice the officer in departmental proceedings, which must afford him full opportunity to respond.

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Criminal Procedure Bail and Custody Police Conduct and Accountability Constitutional Jurisdiction Judicial Propriety Investigative Process Child Sexual Abuse Departmental Action

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