Meghalaya High Court Quashes Charges Against Former Education Minister And Others In 2008 Teacher Recruitment Case
The Court held that, given the absence of prima facie evidence, coupled with the inordinate delay, continuing the criminal proceedings would amount to an abuse of process of law.
The Meghalaya High Court has quashed criminal proceedings against the former Education Minister of Meghalaya and other senior officials of the Education Department in connection with alleged irregularities in the recruitment of School teachers in 2008.
Exercising powers under Sections 227 and 482 of the Code of Criminal Procedure, the Court held the material placed on record insufficient to frame charges and that the long delay in prosecution had rendered the proceedings unsustainable.
The Court was hearing a petition challenging the order of a Special Judge (CBI), who had refused to discharge the accused and directed that charges be framed against them.
A Bench comprising Justice W. Diengdoh, while delivering the judgment, observed that “…applying the principles laid down in the above Supreme Court decisions, if the prima facie case sought to be made out by the prosecution, from the documents, records and other evidence is so weak that a reasonable suspicion of the accused having committed the crime does not arise, the Court on consideration of this evidence is empowered to discharge the accused. In this case, the prosecution has failed to establish even a prima facie case from where a reasonable suspicion may arise in the prosecutor or the court of interpolation of the score sheets by the accused or any of them. The case or charges against each of them falls to the ground.”
Advocate N. Mozika, DSGI appeared for the petitioner Bureau, while the respondents were represented by Senior Advocate Salman Khurshid.
Background
The case originated from a complaint alleging manipulation in the appointment of Teachers in Lower Primary Schools in 2008. It was alleged that the then Education Minister, in conspiracy with some other senior officials, had interfered in the selection process by influencing the merit list prepared for recruitment.
The CBI then, on a reference made by the Meghalaya High Court, investigated the alleged irregularities and subsequently filed a chargesheet. Based on it, the Special Judge (CBI), in August 2022, ordered framing of charges against the then Education Minister and two senior officials of the department.
Aggrieved, the accused approached the High Court seeking the quashing of the proceedings. They argued that the allegations were politically motivated, that the material relied upon by the prosecution was insufficient, and that the prolonged delay of nearly 17 years violated their right to a fair trial.
Court’s Observations
The Court examined the material placed on record, including the CBI’s chargesheet and supporting documents. It was observed that there was no substantive evidence showing direct involvement of the accused in manipulating the recruitment process. The Court further noted that while allegations of interference were made, they were not supported by evidence linked to the charge of interference by the accused.
Noting that the criminal proceedings had been pending since 2008 without meaningful progress, the Court stressed that subjecting the accused to trial after such an inordinate lapse of time, without adequate evidence, would amount to harassment and an abuse of process.
The Bench reasoned that the powers under Sections 227 and 482 CrPC exist to prevent such abuse, and that the case at hand fit squarely within this principle.
“Therefore, exercising power under Section 227 of the Code read with Section 482, especially the part which deals with the power of the court to prevent abuse of the process of any court or to secure the ends of justice, I set aside the impugned order dated 23rd August, 2022 passed in Special (CBI) Case No. 2 of 2020 by the learned Special Judge (CBI), East Khasi Hills district, Shillong”, the Court concluded.
Conclusion
Allowing the petition, the Court quashed the impugned order and discharged the accused. It held that the charges framed against the former Education Minister and the two senior officials of the Education Department could not be sustained either on facts or in law.
Cause Title: The Central Bureau of Investigation v. M. Ampareen Lyngdoh & Ors. (Neutral Citation: 2025:MLHC:800)
Appearances
Petitioners: Dr. N. Mozika, DSGI, with Advocates K. Chisa and K. Gurung.
Respondents: Senior Advocates S. Khurshid & K. Paul with Advocates S. Ain, R. Goyal, S. Panthi, B. Snaitang, S. Chanda, C.C.T. Sangma.
