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Withdrawal From Prosecution Under Section 321 CrPc

Once a prosecution is launched, its relentless course cannot be halted except on sound considerations germane to public justice.[1]
The above line contains within itself the principle on basis of which a Public prosecutor proceeds to apply for withdrawal from prosecution. This principle lies entrenched in the section 321 of Criminal Procedure Code of 1973.

Since the State is responsible for prosecuting the offender in criminal justice system, the Public Prosecutor who acts as a representative of the government in the court and as an officer of the court assumes prime importance in justice delivery. Under s. 321, the Public prosecutor is empowered to withdraw from prosecution after consent of the court at any stage before the judgement is pronounced.

The process of withdrawal from prosecution has as its prime actor – the Public Prosecutor or the Assistant Public prosecutor, and as supervisor – the court. In this process, as envisaged by the section itself, there is no role of the government. However, in practical reality, the government is the executive concerned with prosecution and therefore inherently has major say. Since the Public Prosecutor is appointed by the State government, it has a relationship of agent-principal with the government which indeed becomes the source of all interpretative and practical problems.

In this article, the important aspects of the S. 321 of Cr.P.C. have been looked into with detail. Further, the position of Public Prosecutor vis-à-vis the state government in deciding the withdrawal from prosecution shall be discussed and analysed through case laws and relevant provision. Also, the role of court as supervisor in giving consent to the application shall also be analysed with help of case laws. And lastly, the position in law of the victim or any third party in relation to his or her locus standi for opposing the application of withdrawal from prosecution has also been analysed.

Understanding Section 321

Section 321 of Criminal Procedure Code, 1973 deals with the aspect of withdrawal from prosecution by the Public Prosecutor. This section corresponds to S. 494 of the old Cr.P.C. The new section is different from the archaic one in mainly two aspects. One, in earlier section, the phrase in-charge of a case[2] was not present which led any public prosecutor to withdraw a case. In the new section, only the Public prosecutor or Assistant public prosecutor who is in-charge of the particular case may apply for withdrawal from prosecution. Second, in the new section, clauses (i) to (iv) have been added to require permission from the Central government for the Public prosecutor to withdraw from prosecution in cases related with the Central government.

Section 321 of the Cr.P.C., 1973 reads as follows:

321. Withdrawal from prosecution.- The Public Prosecutor or Assistant Public Prosecutor in charge of a case may, with the consent of the Court, at any time before the judgment is pronounced, withdraw from the prosecution of any person either generally or in respect of any one or more of the offences for which he is tried; and, upon such withdrawal,

  1. if it is made before a charge has been framed, the accused shall be discharged in respect of such offence or offences;
  2. if it is made after a charge has been framed, or when under this Code no charge is required, he shall be acquitted in respect of such offence or offences:
    Provided that where such offence-
    (i) was against any law relating to a matter to which the executive power of the Union extends, or
    (ii) was investigated by the Delhi Special Police Establishment under the Delhi Special Police Establishment Act, 1946 (25 of 1946 ), or
    (iii) involved the misappropriation or destruction of, or damage to, any property belonging to the Central Government, or
    (iv) was committed by a person in the service of the Central Government while acting or purporting to act in the discharge of his official duty, and the Prosecutor in charge of the case hag hot been appointed by the Central Government, he shall not, unless he has been permitted by the Central Government to do so, move the Court for its consent to withdraw from the prosecution and the Court shall, before according consent, direct the Prosecutor to produce before it the permission granted by the Central Government to withdraw from the prosecution.[3]


The Legislative Intent behind the section

Any crime is said to be committed not against just the individual but the entire society. Since the entire society is injured by the act of the accused and since the entire society cannot practically sue the accused person, the State arrogates the power and responsibility to initiate prosecution against the offender. It is not the case that the private individual cannot initiate a prosecution or that he or she cannot be represented by counsel of his or her choice, but such counsel will be supervised by the public prosecutor. Thus, generally the Public Prosecutor or the Assistant Public prosecutor is the authority responsible to conduct the case against the accused in the court of law.

There may be some occasions in which the Public prosecutor does not find enough evidence to further the prosecution case against the accused or that he or she realises that furthering the prosecution case will lead to negating the prosecution evidence or that furthering the prosecution may not be in the interest of public justice, peace or tranquillity. The legislature provided the leeway to the public prosecutor and thus the state government to end such cases furthering which the larger public interest may be compromised. Thus, the section 321 provides discretion to the Public Prosecutor to withdraw from prosecution, with the consent of the court, in such cases wherein he or she thinks such withdrawal will lead to larger public interest being served.

Scope and Applicability

Some special laws which deal with terrorist related activities like POTA (repealed), UAPA do not per se have applicability of s. 321 Cr.P.C. but the principle of judicial review still applies which is the essence of s. 321 Cr.P.C. Thus, even if s. 321 does not apply in its form as written down in Cr.P.C., the principle of judicial review is applicable in all special laws in regard to power of court to give consent to the withdrawal application from prosecution filed by public prosecutor.[4]

Discharge and Acquittal when ordered?

According to clause (a) of s. 321, if the application for withdrawal from prosecution is made before charges are framed and the court consents to such application, then the accused is discharged in respect of the offences he or she was charged with.

According to clause (b) of s. 321, if the application for withdrawal from prosecution is made after the charges have been farmed and the court consents to the application, then the accused is acquitted in respect of the offences he or she was charged with.

Interpretive issues in s. 321

Section 321 broadly comprises of three interpretive areas which have been dealt with by the courts since the code came into existence.

First interpretative issue is – Who can apply for withdrawal from prosecution? This issue has within itself deep seated convoluted issues of interpretation. For instance, when prosecutor or assistant public prosecutor is referred to in section what agency does the government have in dictating the decision of the prosecution, on what basis the public prosecutor applies for withdrawal from prosecution, and, how much role does the government play in influencing the decision of the prosecutor.

Second interpretative issue is – the consent of the court. This issue has also been widely discussed in courts of law. At the outset, it may seem pretty simple to understand, but the complexities surrounding the consent of the court are numerous. For instance, can the court consent without adducing reasons, can the court decline the application without adducing reasons, and, what all does the court have to examine before consenting to the application.

Third interpretative issue is – the victims locus standi. This issue although of grave importance is given lesser importance in interpretative arenas. The case at the outset was initiated because it injured the victim primarily and then the society, but, the State in building up the theory of Parens Patriae happily forgets the concerns of the victim concerned. The State executive sometimes can sway into political considerations which are antithetical to the interest of public and apply for withdrawal from prosecution. The victim or any other person also should have a locus standi before the court entertaining application for withdrawal from prosecution to oppose such application.

These three issues will be considered in greater detail in the upcoming chapters.

Who Can Withdraw?

According to the section 321, only the public prosecutor or the assistant public prosecutor who is in charge of a particular case can apply for withdrawal from prosecution in the respective case. Also, a public prosecutor cannot apply for withdrawal from prosecution in case of private complainant.[5]

Although, the section provides no grounds on which withdrawal from prosecution can be filed by the Public Prosecutor, the essential inherent condition read into the section by the Supreme Court is that withdrawal should be in the interest of administration of justice. It is the responsibility of the respective court, in which the withdrawal application has been filed, to scrutinize the reasons behind the withdrawal and check that withdrawal is not sought on reasons extraneous or against the interest of justice. Furthermore, it is the duty of the court to see that the Public prosecutor actually applies his or her free mind and not just act as mere mechanical agent of the State government.[6]

The courts in various cases have burdened the public prosecutors with enormous responsibility to apply their own free mind and even go against the opinion of the State government if need be. However, the reality is convoluted. The section envisages free application of mind of the concerned public prosecutor without intervention from any government except when explicitly required in law. On the other hand, the Supreme Court itself conceded to the point in Sheonandan Paswan v State of Bihar[7] that the Public Prosecutor is appointed by the State Government and enjoys office on pleasure of government, thus, being more of an agent of the government than an independent officer of the court. This observation of the Supreme Court is very close to reality indeed.

The courts have interpreted the entire situation as follows: The State government can give instructions or opinions to the Public Prosecutor in regards to withdrawal of a case on ground of policy, public justice, vexatious prosecution, etc., but the Public Prosecutor has to apply his free mind on to the recommendation of State government and then may decide on reasons to either withdraw from prosecution or continue. If he decides to withdraw, then he must give reasons to the court and prove that he applied his free mind on to the pertinent case. On the other hand, if he decides to continue with the prosecution then he is not left with any other option but to resign from his post.[8]

Thus, the aspect of free application of mind by the public prosecutor on withdrawal from criminal prosecution is contentious and bristled with practical problems. The literal connotation that public prosecutor or the assistant public prosecutor is responsible for bringing out the application for withdrawal from the prosecution seems to be quite distant from the reality wherein the State government have indeed acquired a central role in determining the fate of the withdrawal from prosecution process.

The answer to question, who can withdraw? is certainly the Public Prosecutor or the Assistant Public Prosecutor in-charge of the case, but, in actual reality this power is often used by the State government due to the relationship of Agent and Principal between the Public Prosecutor and the State.

The Supreme Court in Sheonandan paswan v State of Bihar[9], observed that albeit the Public Prosecutor is the officer of the court but he is also the agent or representative of the government and thus, he is bound to follow the advice or opinion of the government or leave the post.

Discretion of Public Prosecutor

The public prosecutor is, under the section, endowed with unfettered discretion in deciding what cases to be applied for withdrawal. Nonetheless, such discretion is not unreviewable and, as provided in the section itself, is subject to courts supervisory function. In the case of M.N. Sankarayarayanan Nair v P.V. Balakrishnan[10], the Supreme Court tried to outline the guideline in regard to which the public prosecutor can exercise his or her discretion. The court observed that the discretion is guided by the implicit requirement that the withdrawal should be in the interest of administration of justice. Such may include that prosecution is unable to collect enough evidence to sustain charges on accused, or that withdrawal is necessary for controlling law and order situation, or for maintenance of public peace and tranquillity etc.

The Supreme Court in Rajender Kumar Jain v State[11], observed that in cases when going ahead with prosecution causes or threatens to cause violence, mass agitations, communal violence, student unrests etc., it is okay and in the interests of public for the public prosecutor to withdraw from prosecution in such particular cases. The court further observed that when deciding between going forward with prosecution and withdrawing from prosecution in cases which threaten the peace of public, the state government is right in withdrawing from the prosecution. The court held that the narrower public interest of prosecuting the accused ought to be jettisoned for securing larger public interest of maintaining peace and tranquillity in society.

What exactly constitutes public interest?

The condition that public prosecutor can seek withdrawal from prosecution on basis of securing greater public interest has proven to be vague and the executive has numerous times misused this vagueness around this condition for securing its self-serving political interests. Although an exhaustive definition for public interest is difficult to prepare, the courts have determined the decision of executive on the scale of public interest in light of the facts and circumstances of cases.

For instance, in State of U.P. v III Additional District & Sessions Judge[12] , the state government sought to withdraw from prosecution against an infamous lower caste woman dacoit, Phoolan Devi, who committed various crimes like murder, dacoity, etc., against some higher caste people just to treat them a lesson so that they do not commit atrocities against lower caste people. The Public prosecutor in charge sought to withdraw giving reason that the accused was forced into such crimes due to the various atrocities committed upon her by the higher caste people.

However, the court reasoned that there is no service to the public interest in withdrawing from prosecution in particular case and rather such withdrawal might lead to caste based wars wherein every person would think himself or herself to take revenge of any atrocities committed by another without taking recourse to lawful authorities creating chaos and utter savageness.

In State of Punjab v Union of India[13] , the State government took a policy decision to withdraw from prosecution against the employees of P&T Department in cases where there is no trace of personal violence or material destruction. The Public Prosecutor filed application for withdrawal under then section 494 of the old Cr.P.C. The Magistrate accepted the application but High Court set aside the acquittal. The Supreme Court on appeal, held that the public prosecutor can on opinion of the State government seek withdrawal from prosecution in public interest. In the particular case, the court held that firstly, the court only needs to act as supervisor i.e., check that the office of public prosecutor has not been used for purposes other than to serve the interests of public justice. Secondly, again opening of trial may lead to public unrest amongst the employees.

Role of State government in cases when larger public interest is involved
Although, as has been established in various Supreme Court cases that it is the public prosecutor who is solely responsible for deciding whether to file and for filing applications for withdrawal from prosecution, the Supreme Court in Rajender Kumar Jain v State[14] held that in cases where large and sensitive issues of public policy and interest are at stake, the public prosecutor ought to take advice from the State government because the public prosecutor does not have the requisite source of information and resource to determine the matter effectively.

The extent of discretion
The Supreme Court in Sheonandan Paswan v State of Bihar[15] reiterated the law dictated in Ram Naresh Pandey case relating to the extent of discretion of the public prosecutor vis-à-vis the State government. The court held that the State is responsible for bringing the accused who commits crime against the society to justice.

Thus, it is the prerogative of the State to withdraw from prosecution. The Public Prosecutor may apply his independent and free mind and come to the conclusion. If he or she concludes that prosecution should be withdrawn then he may apply to the court with reasons. And, if he or she concludes that case ought not to be withdrawn then he has two options – either to ask the government to relieve him from the particular case lest he shall have to resign, or to forward the application and then while hearing of the application give his or her considered opinion that such application is not sustainable on grounds set out by him or her.

However, there are certain cases also which effectively bolster the view that the public prosecutor has to apply his free mind and is not act as merely a post box of the state government. In S.K. Shukla v State of U.P.[16], the court observed that the office of public prosecutor is important and cannot be used by the state government to fulfil their political desires as per own whims and fancies. The public prosecutor being an officer of the court has to act on his free mind and decide on the issue of withdrawal of application.

The contrasting decisions of the Supreme Court in regard to extent of discretion to Public prosecutor vis-à-vis the State Government have puzzled the situation. However, when observed in terms of pragmatism and practical application, the Supreme Court decision in Sheonandan Paswan[17] seems to be of greater relevance and authority because in this non-ideal world, the State governments are not usually inclined to hear criticism or denial from its employees or agents like Public Prosecutors and therefore whenever such officials like Public Prosecutors tend to give advice contrary to opinion of the executive, the officials have to resign or reluctantly follow the opinion of the government.

Can the application to withdraw from the prosecution be withdrawn by the Public Prosecutor?

The Supreme Court in N. Natarajan v B.K. Subba Rao[18] and M/s V.L.S. Finance Ltd vs. S.P. Gupta[19] held that the office of Public prosecutor is not post office and he or she is responsible to the court and the collective. Further, it held that the public prosecutor has to act independently when considering the issue of withdrawal from prosecution. Also, the court held that as long as the application by the prosecutor is in the interests of public justice, the application to withdraw the application for withdrawal from prosecution can be heard by pertinent court.

Consent of Court

What does the word court refer to?
At the outset, although it may seem to be simple to answer but when actually asked to answer the question may seem tricky. Is it the court which makes inquiry and commits the case to the court of proper jurisdiction or the court which tries the matter, which is being referred in the section?

The Supreme Court in Rajender Kumar Jain v State[20], held that the expression judgement is wide enough to include in its purview both the courts- court of Committing Magistrate and that of Court of Session. Thus, both the courts have authority to hear application for withdrawal from prosecution from the Public Prosecutor.

The section 321 does not provide any guidelines to be followed by court in determining whether to give consent to the withdrawal application or not. Thus, the court literally has unfettered discretion as regards to giving consent to the application for withdrawal from prosecution filed by prosecutor in charge of case. However, the Supreme Court has formulated through various judgements guiding principles to be followed by courts in giving consent to withdrawal application.

First, the court should give consent only when it is satisfied that such grant of permission for withdrawal from prosecution would serve the interests of justice and would not undermine the principles which the executive is bound to uphold and follow.

In Bansi Lal v Chandan Lal[21] , a criminal case was registered under various sections of IPC against the accused persons. The case was committed to the Court of Sessions after the charges were framed. The Public Prosecutor at this stage filed an application for withdrawal from prosecution on ground that the prosecution does not want to produce evidence and continue the criminal proceedings against the accused persons. The court accepted the application. On revision, the High Court also upheld the trial court decision.

The Supreme Court on appeal held that the trial court cannot mechanically give permission to withdraw from prosecution to the public prosecutor. The court has to see that the grounds adduced in favour of withdrawal are actually in the interests of justice and public interest. The court also has to see whether the office of public prosecutor is misused by the executive to fulfil the narrow interest motivated by politics.

Second, the court while giving consent to withdrawal from prosecution acts as a supervisor and thus, generally, the court should not re-appreciate the grounds on which the public prosecutor decided to apply for withdrawal. The court, however, is duty bound to examine whether or not the public prosecutor applied his free mind in deciding the matter. Thus, it is the courts important duty to scrutinize every application for withdrawal from prosecution in regards to application of free mind by the public prosecutor in charge of the particular case.

In Sheonandan Paswan v State of Bihar[22], the Supreme Court held that the court hearing the application for withdrawal from prosecution acts as a supervisor and thus need not to go into the evidence of the case concerned. The court should not be concerned with what the result would be if all the evidence is considered. All the court should be concerned with is that in considering the material placed before it, whether the public prosecutor applied his free mind and whether the reasoning adopted by him suffers from inherent perversity which may lead to injustice.

Third, notwithstanding the fact that court generally is not duty bound to look into the grounds on basis of which the public prosecutor in charge filed the application, the court may look into the grounds to uphold the interests of public when the reasoning of the public prosecutor does not pass the test of reasonable man or such is perverse to the justice.

For instance, in Abdul Karim v State of Karnataka[23], when the consent of the court was sought by the public prosecutor in charge for withdrawal from prosecution against some notorious criminals, the Supreme Court did not allow such application. The Supreme Court observed that albeit the court is not required to examine the grounds which led the public prosecutor in charge to apply for withdrawal from prosecution, the court shall have liberty to re-examine them if the reasoning adopted by the public prosecutor seem to be perverse to the public justice or such is not in consonance with the reasonable man standard.

Victims Locus Standi

The section 321 is silent on the locus of the victim, complainant or any other person to oppose the application of withdrawal from prosecution filed by public prosecutor in charge. In Sheonandan Paswan v State of Bihar[24] , the appellant applied before trial court to initiate proceedings under section 302 of IPC against the accused while at the same time the prosecutor was applying for withdrawal from prosecution in the same case.

The court rejected the application of the appellant and granted the permission to public prosecutor in charge to withdraw from prosecution. Something of the similar nature also happened in Subhash Chander v State[25]. In this case, the private complainant opposed the application for withdrawal from prosecution, but the application was permitted to be withdrawn.

The burning issue of the locus standi of the complainant or any other person to oppose the withdrawal application has not been decided by court conclusively. In cases like State of Bihar v Ram Naresh Pandey[26], Rajender Kumar Jain v State, Sheonandan Paswan v State of Bihar and M.N. Sankarayarayanan v P.V. Balakrishnan, the Supreme Court on the opposition raised by the complainant did hear the matter and decided but held also such to be outside the locus standi of the complainant. On the other hand, various High courts like that of Kerala, Bombay and Nagpur have upheld the locus standi of the private persons or complainant to oppose the withdrawal application.

But, High courts situated in Patna, Delhi and Calcutta have taken a divergent view that private person and complainant do not have locus standi to oppose the withdrawal application.

It becomes travesty of justice when a private person who is indeed the victim of the crime is not allowed to oppose the withdrawal application. The state has the authority to prosecute the accused on behalf of the society and victim but when the state does not fulfils this obligation due to various reasons, the victim or the person from the community against whom also the crime is committed as he is also equal part of community as the victim, should have the locus standi to oppose the withdrawal application.

There are indeed some cases which seem to be in right direction. The Andhra Pradesh High Court in M. Balakrishna Reddy v Principal Secretary to Govt. Home Deptt.,[27] held that an individual not being the victim of the crime is equally endowed with right to oppose the withdrawal application from prosecution as is the victim of the crime. Further, the court observed that the third person is part of the community against whom the crime ha been committed and thus he or she has locus standi to oppose the withdrawal application.

In V.S. Achuthanandan v R. Balakrishna Pillai[28] , the Supreme Court accepted the locus standi of the opposition leader in opposing the withdrawal application from prosecution against a minister since no one else was opposing such application.

Thus, at present, the trend seems to be more in favour of the recognition to victims and third partys locus standi in opposing the application for withdrawal from prosecution.

Conclusion
Withdrawal from prosecution is an important aspect of the criminal procedure in India. The Public Prosecutor or the Assistant Public Prosecutor who are considered as officers of the court and also as the agents or representatives of the state government play a key role in determining withdrawal from the prosecution.

The binary role played by the Public Prosecutor has indeed become the source of problem in discharging this function inasmuch the Public prosecutor is expected to fulfil the demands of both the distinct pillars of democracy with full faith which seems far from reality.

The Public Prosecutor on one hand is expected to help the court, as the officer of court, in bringing truth to the fore and on the other hand, as the agent of the government, expected by the government to represent the case in favour of its policy. Thus, the discretion offered by the section 321 onto the Public prosecutors or the Assistant Public Prosecutors seem to be founded not in them but in the State governments because as recognised by the Supreme Court itself in Sheonand Paswan case that in spite of Public prosecutor being an officer of court, he also shares a relationship of agent-principal with the state government and thus, he is required to follow the opinion of the state government or leave.

Therefore, the culminating effect of all this is that the public prosecutors generally surrender this discretionary powers in front of the state government for the sake of their job and thus ultimately risking the public justice. However, there is a safeguard though weak which provides the guidelines on basis of which the public prosecutor can seek withdrawal from prosecution. The essential condition being that such withdrawal should lead to service of larger interest of public justice.

The section has also provided stronger buffer against this above-mentioned shock to the justice delivery system. This buffer is the requirement of consent of the court. the courts consent is required before a case may be withdrawn from the prosecution.

The court is expected to examine the flaws which could come in due to the hazardous binary position of the Public prosecutor and its relationship of agent-principal with the executive. The court therefore, looks whether the Public prosecutor applied his free mind onto the matter and secondly, whether such application of mind was up to the standard of reasonable man, that is, not perverse to the interests of public justice. Thus, the court can dismiss the application if its finds that the public prosecutor did not apply his or her free mind on to the matter at hand or that such application was so perverse to the justice that no reasonable man would come to such conclusion.

Last but not the least, the issue of Victim and third partys locus standi has gained prominence in legal circle. Erstwhile, the courts did not recognize the locus standi of the victim or any other person in opposing the application of withdrawal from the prosecution. However, in later case, the Supreme Court has recognised the third party or victims locus standi in opposing the application.

Overall, the section does suffer from infirmity due to the lack of clarity as regards to the extent of discretion of the public prosecutor which lands him or her in the precarious position in which he has to either choose his job or the justice, and, sadly, favoured option remains the job. The discretion of public prosecutor has to be defined clearly so that he can exercise his discretion as expected in the law for the furtherance of justice.

End-Notes
[1] Subhash Chander v State Chandigarh Administration and Others (1980) 2 SCC 155.
[2] Criminal Procedure Code 1973, s 321.
[3] ibid.
[4] Mahmadhusen Abdulrahim Kalota Shaikh v Union of India (2009) 2 SCC 1.
[5] State of Punjab v Surjit Singh AIR 1967 SC 1214.
[6] Sheonandan Paswan v State of Bihar (1987) 1 SCC 288.
[7] ibid.
[8] Sheonandan (n 6).
[9] Sheonandan (n 6).
[10] (1972) 1 SCC 318.
[11] (1980) 3 SCC 435.
[12] 1997 Cri LJ 3021 (All).
[13] (1986) 4 SCC 335.
[14] Rajender (n 11).
[15] Sheonandan (n 6).
[16] (2006) 1 SCC 314.
[17] Sheonandan (n 6).
[18] (2003) 2 SCC 76.
[19] (2016) 3 SCC 736.
[20] Rajender (n 11).
[21] (1976) 1 SCC 421.
[22] Sheonandan (n 6).
[23] (2000) 8 SCC 710.
[24] Sheonandan (n 6).
[25] Subhash (n 1).
[26] AIR 1957 SC 389.
[27] 1999 Cri LJ 3566 (AP).
[28] (1994) 4 SCC 299.

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