He filed a complaint about a police custody death. The police charged him with murder.

He went to the police station to report a death. He walked out as an accused in the murder.

Ram Prakash Chadha owned a wood business in Uttar Pradesh. On a July morning in 1993, he walked into the Modi Nagar police station to file a complaint. His cashier, Ram Kishore, had died in police custody after being held for six days. Chadha wanted the officers responsible to be punished. Instead, the investigation turned on him. Seven years later, the CBCID's (the state's Criminal Bureau of Investigation) chargesheet named Chadha as Accused No. 3 in the same murder.

When the cashier didn't come back

The story began with a robbery. Chadha sent his cashier Ram Kishore and another employee to collect money for the business. On their way back, two men stopped them at gunpoint and took the cash. Chadha filed an FIR (a written complaint that starts a police investigation) the same day.

The police investigated. They decided the robbery complaint was false. On July 17, 1993, Chadha called Ram Kishore through an employee and brought him to the Modi Nagar police station for questioning about the alleged fake robbery. The police kept Ram Kishore there without any legal authority for six days — from July 17 to July 23. During those days, they interrogated him. They tortured him. On July 24, Ram Kishore died in a hospital.

The complaint that backfired

Chadha did what any citizen would do. He went to the same police station and filed a complaint about the custodial death — a death that happened while the victim was in police custody. The case was registered as Crime No. 371 of 1993. The investigation was eventually handed over to the CBCID.

In February 2000 — nearly seven years after the death — the CBCID filed its chargesheet. It named three accused: a police inspector, a sub-inspector, and Ram Prakash Chadha. Chadha was charged with murder under Section 302 IPC, criminal conspiracy under Sections 120A and 120B IPC, and common intention under Section 34 IPC, along with several other provisions including wrongful confinement (Section 343) and causing hurt to extort confession (Section 330).

The man who reported the crime was now a co-accused in it.

Why the charge against Chadha made no sense

Chadha's lawyers argued a simple point: there was nothing in the police file that connected him to any conspiracy to kill his own cashier. He had reported the robbery. He had brought Ram Kishore to the station for inquiry — not for torture. He had filed the complaint about the custodial death. Where was the meeting of minds? Where was the agreement to commit an illegal act?

The prosecution's case, as presented in the chargesheet, appeared to rest on the idea that because Chadha brought Ram Kishore to the police station, he must have known what the police would do to him. But the chargesheet did not point to any specific document, any witness statement, or any piece of evidence that showed Chadha and the police officers had agreed to torture and kill Ram Kishore.

The long road to the Supreme Court

Chadha filed an application under Section 227 of the CrPC (the provision that allows an accused person to ask for discharge — to be let off — if the prosecution's own documents show no case against them). The Additional Sessions Judge in Ghaziabad rejected it in April 2007. Chadha then went to the Allahabad High Court under Section 482 CrPC (the High Court's inherent power to prevent abuse of its process). The High Court dismissed his petition in April 2023.

Sixteen years after his first discharge application was rejected, Chadha reached the Supreme Court.

What the Supreme Court looked at

The bench of Justice C.T. Ravikumar and Justice Sudhanshu Dhulia examined a narrow but critical question: Did the prosecution's own documents — the chargesheet, the witness statements, the case diary — contain any material that could even prima facie (at first glance) establish that Chadha was part of a criminal conspiracy or shared a common intention with the police officers?

The court applied a well-settled principle from its earlier judgments. At the stage of discharge under Section 227 CrPC, the judge can only look at the record of the case and the documents submitted by the prosecution. The judge cannot consider defence materials. The judge can sift and weigh the prosecution materials for the limited purpose of deciding whether a prima facie case exists. But the judge cannot assess the admissibility or evidentiary value of those materials — that would be doing the trial judge's job too early.

The test, the court said, is this: strong suspicion sufficient to frame a charge must emerge from the materials brought on record by the prosecution. It cannot be based on suppositions, suspicions, and conjectures that have no foundation in the material before the court.

Why the conspiracy charge collapsed

To constitute even an accusation of criminal conspiracy under Section 120B IPC, the court held, there must at least be an accusation of a meeting of minds between two or more persons for doing an illegal act. Simply using the words "criminal conspiracy" in a chargesheet, without any supporting material that discloses an actual agreement, is not enough to frame a charge.

The court examined the record. It found nothing that showed Chadha and the police officers had agreed to kill Ram Kishore. Chadha had brought the cashier to the station for inquiry — that was a fact. But from that fact alone, no inference of a conspiracy could be drawn. The court also noted that Chadha himself had filed the complaint about the custodial death. It would be extraordinary for a co-conspirator to walk into a police station and report the very crime he was supposedly part of.

The bench also found that the trial court and the High Court had failed to give adequate reasons for rejecting the discharge application. When an application under Section 227 CrPC is filed, the court must disclose its reasons — even if not in great detail — for finding a sufficient ground or prima facie case against the accused. This is necessary, the Supreme Court said, so that a superior court can examine whether the rejection was correct.

What this means for every accused person

This judgment is a reminder that the discharge stage under Section 227 CrPC is not a formality. It is a real safeguard. If the prosecution's own documents do not contain material that can even raise a strong suspicion against an accused, the court must discharge them. The accused does not have to wait for a trial to prove innocence. The judge must look at the file and decide whether the case should go to trial at all.

THE PLAY: If the prosecution's own chargesheet and documents contain no material showing an agreement or common intention, the accused must be discharged — the court cannot send a person to trial based on mere labels in the chargesheet.

The walk-off

The Supreme Court set aside the orders of the trial court and the High Court, allowed Chadha's discharge application, and ordered that he stand discharged from the case. The man who reported a custodial death walked out of the courtroom — finally — without a single charge against him.