The Supreme Court on Wednesday brought an end to criminal proceedings against former Prime Minister Manmohan Singh in the coal block allocation case, setting aside the trial court's order that had summoned him as an accused. The ruling came after the apex court accepted the Central Bureau of Investigation's (CBI) closure reports, effectively clearing Singh and the other accused of criminal liability in the matter. A Bench comprising Chief Justice Surya Kant, Justice Joymalya Bagchi and Justice V. Mohan accepted the CBI's findings that no prosecutable case was made out against the accused. The judgment held that the trial court was not justified in rejecting the CBI's closure reports and proceeding to take cognisance of the case.
The Bench observed that although the appeal could have been treated as infructuous following the demise of Manmohan Singh, it chose to examine the legal issues involved because of their wider significance. The court said it was necessary to determine whether the Special Judge had acted correctly in summoning the former prime minister despite two closure reports submitted by the investigating agency. "Although the appeal could have been disposed of as infructuous owing to the unfortunate demise of the appellant, we have examined the issue of the learned Special Judge taking cognisance and summoning the appellant after considering both closure reports filed by the CBI," the Bench observed in its judgment.
The coal block allocation case stemmed from allegations of irregularities in the allocation of coal mining blocks during the previous United Progressive Alliance (UPA) government. Several cases were registered following scrutiny of the allocation process, with the CBI investigating allegations of corruption, abuse of office and procedural violations in different coal block allotments. In the specific case involving Manmohan Singh, who also held the Coal Ministry portfolio for a period during his tenure as prime minister, the CBI had filed closure reports after concluding that the available evidence did not support criminal prosecution. However, the Special CBI Court had rejected those reports and summoned Singh and other accused to face trial.
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The Supreme Court has now ruled that the trial court's decision to disregard the investigating agency's conclusions was legally unsustainable. By accepting the CBI's closure reports, the apex court has effectively brought the proceedings against Singh and the remaining accused to a close. The judgment also underscores the principles governing judicial consideration of closure reports submitted by investigating agencies. While courts have the authority to disagree with an investigating agency's conclusions, the Supreme Court indicated that such decisions must be supported by adequate legal justification and careful evaluation of the material on record.
The ruling marks the final judicial chapter in one of the cases arising out of the broader coal allocation controversy, which dominated India's political and legal landscape for years. The issue had prompted multiple investigations, prosecutions and legal challenges involving public officials, bureaucrats and private entities linked to coal block allocations. With the Supreme Court's decision, the criminal proceedings against the late former prime minister stand formally closed, bringing legal closure to the case. The verdict also clarifies the position of the other accused covered by the CBI's closure reports, who have likewise been cleared of criminal liability in the matter.
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