The Supreme Court noted that when the allegation upon which a FIR was formed does not disclose any act of the accused or their participation in the commission of crime, the criminal proceedings may be invalidated.

The appeals court's panel of Justices Ajay Rastogi and CT Ravikumar remarked that the High Court had not looked into the specifics of the complaint or how the current defendants are connected to the purported alleged crime in any way.

The court then referred to the guidelines issued in State of Haryana and Others v. Bhajan Lal and Others especially the following categories: "Where the uncontroverted allegations made in the FIR or complaint and the evidence collected in support of the same do not disclose the commission of any offence and make out a case against the accused."

Where the allegations made in the FIR or complaint are so absurd and inherently improbable on the basis of which no prudent person can ever reach a just conclusion that there is sufficient ground for proceeding against the accused.

A charge sheet was submitted in this matter under Sections 420, 467, 468, 471, 504, 506, 448, and 387 of the IPC, and a FIR was filed against the accused. They went to the Allahabad High Court to ask for the FIR and Charge Sheet to be thrown out. They moved the Supreme Court since the High Court dismissed the case.

Case Title: Ramesh Chandra Gupta vs State of U P

Citation: P SLP(Crl.) 39 of 2022

Link: https://main.sci.gov.in/supremecourt/2021/32315/32315_2021_6_1501_40093_Judgement_28-Nov-2022.pdf