More than a decade after he was first summoned in the coal block allocation case, former Prime Minister Dr. Manmohan Singh has been cleared by the Supreme Court. The court on Wednesday quashed the 2015 order of a Special CBI Court that had summoned him. It held that the trial court had no justification to reject the CBI’s closure report and take cognizance against him.
A bench of Chief Justice of India Surya Kant, Justice Joymalya Bagchi and Justice V Mohana allowed Singh’s appeal. It accepted the CBI’s closure reports giving him a clean chit and closed the proceedings.
Why the case was heard despite Singh’s death
Singh passed away in December 2024, which could have made the appeal technically infructuous. However, the court chose to examine the legality of the trial court’s order anyway. This was because it contained adverse observations against him that needed addressing.
Appearing for the late former Prime Minister, Senior Advocate Kapil Sibal told the bench, “One of the cases concerns Dr. Manmohan Singh,” and urged the court to expunge the observations made against him. When the Chief Justice suggested the matter could simply be disposed of, Sibal responded that the trial court had taken cognizance and made adverse remarks that deserved to be set aside.
Senior Advocate RS Cheema, appearing for the CBI, noted that questions relating to the validity of certain legal provisions survived in connected matters. In addition, Senior Advocate Abhishek Manu Singhvi added that, at least as far as Dr. Singh was concerned, the adverse remarks could be effaced.
What the court found
The bench recorded that the Special Judge had taken cognizance under the Prevention of Corruption Act against six persons, including Singh, despite the CBI having filed closure reports exonerating him after investigation. “Vide the impugned order, the learned Special Judge took cognizance under the Prevention of Corruption Act against six persons including the appellant, Dr. Manmohan Singh (former Prime Minister of India).
CBI, after investigation, filed closure reports thereby giving clean chit to the appellant. Nevertheless, the learned Judge turned down the closure reports and took cognizance,” the court noted.
On the question of why it proceeded despite Singh’s death, the bench explained: “Due to the unfortunate demise of the appellant, this appeal could be disposed of as infructuous. But with a view to consider the aspect of the learned Special Judge taking cognizance and summoning the appellant, we have gone through both closure reports filed by CBI.”
Having reviewed the reports, the court concluded the trial judge had failed to apply settled principles governing when closure reports filed by investigating agencies should be accepted.
“Having regard to the relevant parameters consistently laid down by this Court on acceptance of reports of the investigating agency, we are satisfied that there was no reason for the learned Judge to turn down the closure reports of the CBI and take cognizance,” the bench held.
The Supreme Court allowed the appeal, set aside the Special Judge’s cognizance order, accepted the CBI’s closure reports, and closed the matter on merits.
The order came during a hearing of a broader batch of coal block allocation matters. In that hearing, the bench also considered whether certain remaining issues needed adjudication by the Supreme Court itself or could be left to the High Courts.
A telling remark from the bar
During the hearing, Sibal offered a brief reflection on how much the political climate around the case had shifted since it began over a decade ago: “Mood of the nation was different then. It’s different today.”
With Singh’s case now closed and his record cleared of the trial court’s adverse findings, the Supreme Court’s attention shifts to the remaining coal block matters still pending before it.
These include questions about which issues warrant its continued involvement versus resolution at the High Court level. How the bench divides that workload in the coming hearings will determine how much longer this decade-plus litigation saga continues for the other accused still awaiting outcomes.
Curated news reports, in-depth analysis, and special features by India’s Opinion editorial team.
