In a major ruling safeguarding the rights of public officials and reinforcing the constitutional guarantee of speedy justice, the Supreme Court of India quashed the criminal proceedings initiated against IAS officer Robert L. Chongthu, who was accused of illegally issuing 16 arms licences during his tenure as District Magistrate, Saharsa, Bihar between 2002 and 2005.
The Court held that the State’s sanction for prosecution under Section 197 CrPC was legally invalid, describing it as a “non-speaking and mechanical order” that failed to demonstrate any meaningful application of mind. The sanction merely recited generic phrases such as “on perusal of case diary documents” without reflecting independent assessment of evidence — a constitutional safeguard designed to protect honest public servants from vexatious prosecution.
The Court also highlighted an extraordinary and unjustifiable delay in the case: although the first supplementary charge-sheet in 2006 explicitly exonerated Chongthu and termed the accusations “false,” the police sought “further investigation” in 2009, resulting in a fresh charge-sheet only in 2020 — a full 11 years later. Trial progress remained stagnant even after cognizance was taken in 2022. The Supreme Court observed that such prolonged delays clearly violated the accused’s fundamental right to a speedy investigation and trial under Article 21 of the Constitution.
Addressing the core allegation of misuse of arms-licensing powers, the Court examined Section 13(2A) of the Arms Act, which permits District Magistrates to issue licences even if police verification reports are not received within the prescribed time. Noting that no statutory timeline existed under the 1962 Arms Rules, the Bench held that while the discretionary power must not be abused, the prosecution had relied on only a single instance of licences allegedly issued within two days — insufficient to demonstrate mala fide or criminal intent.
The Court concluded that the combination of (i) invalid sanction, (ii) long unexplained delay, (iii) earlier exoneration in the 2006 charge-sheet, and (iv) absence of concrete evidence of conspiracy or corruption, rendered the criminal case inherently flawed. Consequently, the Supreme Court quashed the cognizance order dated 1 June 2022, annulled all subsequent proceedings, and reaffirmed that sanctions for prosecuting public servants must be reasoned, independent, and free from external pressure.
The judgment is expected to have significant implications for future cases involving public servants, particularly where administrative decisions are criminalised without adequate evidentiary foundation or where investigative delay violates constitutional protections.
Robert Lalchungnunga Chongthu v. State of Bihar, Decision Date: 21 November 2025