Summary and Analysis of Manchu Mohan Babu vs. The State of Andhra Pradesh
1. Heading
Case Title: Manchu Mohan Babu & Another vs. The State of Andhra Pradesh & Another
Court: Supreme Court of India
Judgment Date: July 31, 2025
Judges: Justice B.V. Nagarathna and Justice K.V. Viswanathan
Citation: 2025 INSC 916
2. Related Laws and Sections
The judgment revolves around the following legal provisions:
Indian Penal Code (IPC), 1860:
Section 290: Punishment for public nuisance.
Section 341: Punishment for wrongful restraint.
Section 171F: Punishment for undue influence/personation at elections.
Section 34: Acts done by several persons in furtherance of common intention.Police Act, 1861:
Section 34: Punishment for offences causing obstruction, inconvenience, or annoyance on roads/public places.Code of Criminal Procedure (CrPC), 1973:
Section 482: Inherent powers of the High Court to quash criminal proceedings to prevent abuse of process.
3. Basic Judgment Details
Appellants: Manchu Mohan Babu (Chairman of an educational institution) and his son, Manchu Vishnu Vardhan Babu.
Respondents: State of Andhra Pradesh and another.
Background:
The appellants organized a rally and dharna on March 22, 2019, protesting the state government’s failure to grant student fee reimbursements.
The rally was conducted during the Model Code of Conduct (MCC) period for the 2019 elections, without prior permission.
An FIR was registered against the appellants under Sections 290, 341, 171F IPC (with Section 34) and Section 34 of the Police Act, alleging public nuisance, wrongful restraint, and obstruction.
The High Court dismissed their petition to quash the proceedings, leading to an appeal in the Supreme Court.
4. Explanation of the Judgment
Key Arguments
Appellants' Contention:
The rally and dharna were peaceful exercises of their fundamental rights (freedom of speech and assembly under Article 19).
No evidence of obstruction, public nuisance, or electoral misconduct (Section 171F IPC).
The MCC does not apply to private citizens, and the prosecution was an abuse of process.State's Argument:
The rally violated prohibitory orders under the Police Act, caused traffic obstruction, and was conducted without permission during the MCC period.
Supreme Court's Analysis
Test for Quashing Proceedings (Bhajan Lal Guidelines):
The Court referred to State of Haryana v. Bhajan Lal (1992) and Pepsi Foods Ltd. v. Special Judicial Magistrate (1998), emphasizing that proceedings can be quashed if:
Allegations, even if accepted as true, do not constitute an offence.
Continuation of prosecution would serve no useful purpose.Absence of Offence Ingredients:
Section 290 IPC (Public Nuisance): No evidence of harm/annoyance to the public.
Section 341 IPC (Wrongful Restraint): No proof of voluntary obstruction.
Section 171F IPC (Electoral Offences): No connection to undue influence or impersonation in elections.
Section 34 Police Act: No act fell under the eight specified offences (e.g., drunkenness, indecent exposure).Fundamental Rights vs. Restrictions:
The rally was peaceful and did not justify criminalization. The state failed to prove reasonable restrictions under Article 19(2)-(3).
Decision
The Supreme Court quashed the FIR and criminal proceedings, holding:
The allegations did not meet the legal requirements of the invoked sections.
The High Court erred in not applying the Bhajan Lal test to prevent abuse of process.
Prosecution would serve no purpose, as the appellants’ actions were protected under constitutional rights.
5. Conclusion
The judgment reaffirms the principle that criminal proceedings cannot be weaponized to suppress legitimate democratic protests. It clarifies the scope of public nuisance, wrongful restraint, and electoral offences, while upholding the right to peaceful assembly. The ruling underscores the judiciary’s role in protecting fundamental rights against arbitrary state action.
Final Outcome:
FIR No. 102 of 2019 and related proceedings quashed.
Appeals allowed in favor of the appellants.
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