The Supreme Court reaffirmed that a third party has the right to file a Special Leave Petition under Article 136 of the Constitution challenging the quashing of criminal proceedings.

The Court stated that an appeal by a private individual can be entertained, but only sparingly and with due caution, referencing the precedents set in National Commission for Women v. State of Delhi & Anr. (2010) 12 SCC 599 and Amanuallah & Anr. v. State of Bihar & Ors. (2016) 6 SCC 699.

The Court mentioned that in the case of P.S.R. Sadhanantham v. Arunachalam & Anr (1980) 3 SCC 141, a 5-judge bench had held that "the Court should be liberal in allowing any third party, having bona fide connection with the matter, to maintain the appeal with a view to advance substantial justice."

The Court rejected Kerala MLA Antony Raju's challenge to the locus standi of a private party that had contested the quashing of criminal proceedings against him. The Court observed that it is the responsibility of the Court to examine the correctness of the High Court's approach, and the issue of locus standi cannot hinder this process.

A division bench of Justices CT Ravikumar and Sanjay Karol was dealing with Raju's challenging to the locus of Green Kerala News Editor-MR Ajayan to file an appeal against quashing of criminal proceedings against him.

"the locus standi of the appellant in SLP(Crl.)No.4887 of 2024, does not come in the way of this Court hearing the same. The case at hand, which has been quashed by the High Court, involves serious allegations of interference with judicial processes which strike at the very foundation of both dispensation and the administration of justice.'' the Supreme Court said.

Briefly, in 1990, Raju, a junior lawyer, was accused of tampering with underwear evidence in a drugs case. While the accused in the case was acquitted, the Kerala High Court directed an investigation into the alleged planting of tampered evidence, which was said to have been part of a criminal conspiracy involving Raju and a clerk.

The High Court quashed the criminal proceedings against Raju but directed that fresh steps be taken based on the allegations. Challenging this, both Raju and Ajayan approached the Supreme Court. One of the key issues before the Court was whether Ajayan had the locus standi to file a special leave petition against the High Court's order.

Raju contended that Ajayan, as a third party, should not be allowed to file an appeal in the criminal proceedings. To support his argument, he relied on the judgments in P.S.R. Sadhanantham v. Arunachalam & Anr., National Commission for Women v. State of Delhi & Anr., and Amanuallah & Anr. v. State of Bihar & Ors..

Upon reviewing the record, the Supreme Court noted that Ajayan had filed an intervention application before the High Court, opposing Raju's quashing petition. The Court also considered the decision in Naveen Singh v. State of U.P., where, in assessing the locus standi of the petitioner, a coordinate bench of the Court had observed that since the allegations concerned tampering with an order of the Court, locus was not that important but, in fact, insignificant with the State not carrying forward the matter.

"Such actions not only erode public trust in the judicial system but compromise the principles of the rule of law and fairness, which are essential for the justice delivery system. Such incidents strike at the foundation of the independence and integrity of the judicial process, hence, it cannot be said that there is a lack of public interest herein. In the peculiar circumstances obtained in this case where the accused allegedly received a material object in question, from the judicial custody, despite there being no specific order for release thereof, and subsequently tinkered/ assisted in tinkering with the same and thereafter substituted it for the original", the Court added.