Pradnya Pranjal Kulkarni Vs State of Maharashtra & Anr. (Supreme Court of India)
The case concerns a challenge to an order of the Bombay High Court which had disposed of a writ petition seeking quashing of an FIR on the ground that the petition had become infructuous after the filing of a chargesheet. The petitioner had invoked jurisdiction under Article 226 of the Constitution as well as Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), seeking quashing of an FIR registered under various provisions of the Indian Penal Code. During the pendency of the writ petition, the police completed the investigation and filed a chargesheet. Relying on a prior Supreme Court decision, the High Court held that once the chargesheet was filed, the writ petition for quashing the FIR had become infructuous, while granting liberty to the petitioner to seek discharge before the trial court.
Before the Supreme Court, the petitioner contended that the High Court had jurisdiction to examine the matter even after filing of the chargesheet, especially since the petition invoked both Article 226 and Section 528 of the BNSS. It was argued that the High Court had misapplied the precedent relied upon, as the earlier decision was rendered in a different factual context.
