Legal Analysis: Narayana Health & Ors. vs. State of West Bengal & Ors

Citation: 2026 INSC 481
Court: Supreme Court of India
Bench: Justice Pamidighantam Sri Narasimha and Justice Alok Aradhe (Division Bench)
Date of Decision: May 12, 2026
Nature of Judgment: Criminal Appeal under Article 136 of the Constitution of India against the judgment of the High Court of Calcutta in a criminal revision petition.

Synopsis of the Judgment

The complainant’s mother was treated at a hospital run by the appellants. After discharge, the complainant discovered that the hospital bill included a charge of ₹2,500 for an HRCT test that was not performed. The hospital admitted the error and offered a refund. The complainant, however, filed a criminal complaint alleging offences under Sections 406 (criminal breach of trust), 420 (cheating), and 120B (criminal conspiracy) of the Indian Penal Code, 1860, and Section 34 of the West Bengal Clinical Establishment (Registration, Regulation and Transparency) Act, 2017. The Magistrate issued summons. The High Court, in revision, set aside the summoning order but remanded the matter for reconsideration of the complicity of certain accused, while observing that an offence under Section 504 IPC (intentional insult) was made out. The Supreme Court quashed the entire criminal proceedings, holding that the allegations, even if taken at face value, did not disclose any criminal offence. The dispute was essentially a civil or regulatory matter concerning a billing error, which the hospital had already offered to rectify. The Court reiterated the principles from Bhajan Lal and held that the High Court should have quashed the complaint instead of remanding it.

1. Basic Information of the Judgment

• Case Title: Narayana Health & Ors. vs. The State of West Bengal & Ors.

• Criminal Appeal Nos.: Arising out of SLP (Crl.) Nos. 10379-10380 of 2023

• Bench: Justice Pamidighantam Sri Narasimha and Justice Alok Aradhe (Division Bench)

• Date of Decision: May 12, 2026

• Citation: 2026 INSC 481

• Appeal From: Judgment and order dated 16.05.2023 of the High Court of Calcutta in CRR No. 967 of 2021 (and connected matters)

2. Legal Framework

Laws and Provisions Involved

• Indian Penal Code, 1860 (IPC): Sections 405 (criminal breach of trust – definition), 406 (punishment for criminal breach of trust), 415 (cheating – definition), 420 (punishment for cheating), 120B (criminal conspiracy), 503 (criminal intimidation), 504 (intentional insult)

• Code of Criminal Procedure, 1973 (CrPC): Sections 200 (examination of complainant), 482 (inherent powers of High Court to quash proceedings)

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