PC Act: More Time Taken For Preliminary Enquiry Not A Ground To Quash Criminal Proceedings: SC Dark secrets of Scotland yard
1. PC Act Case: More Time Taken For Preliminary Enquiry Not A Ground To Quash Criminal Proceedings – Supreme Court
Background
The case concerned allegations of corruption investigated under the Prevention of Corruption Act, 1988 (PC Act).
The accused argued that since the preliminary enquiry took more time than prescribed in Lalita Kumari v. Govt. of U.P. (2014) (where SC directed registration of FIR after preliminary enquiry within 7 days, extendable to 15 days), the entire proceedings should be quashed.
Supreme Court’s Ruling
The Supreme Court rejected this argument.
Held: Delay in completing preliminary enquiry cannot be a ground to quash criminal proceedings under the PC Act.
What matters is whether there is prima facie material of corruption, not how long the enquiry took.
Principle
Procedural delay in preliminary enquiry does not nullify substantive criminal allegations.
Once corruption material is found, investigation and trial must proceed.
2. “Dark Secrets of Scotland Yard”
Meaning
Refers to the mystique, secrecy, and controversies surrounding the functioning of Scotland Yard (the headquarters of the London Metropolitan Police, UK).
Famous for its role in investigating high-profile cases, but also criticized for cover-ups, misconduct, and excessive secrecy.
Dark Secrets / Criticisms
Unsolved Mysteries
Some of the most famous crimes (like Jack the Ripper murders, 1888) were never solved, raising suspicion of incompetence or deliberate concealment.
Political Interference
Scotland Yard has often been accused of shielding political figures from scandals (e.g., corruption and sex scandals involving politicians).
Police Brutality & Misconduct
Allegations of racial bias, wrongful arrests, custodial deaths, and excessive use of force.
Secrecy & Lack of Transparency
Many cases were kept secret under the excuse of “national security” or “public interest.”
This secrecy gave rise to the term “dark secrets”, suggesting that the Yard hides more than it reveals.
Notable Cases
Profumo Affair (1963): Political sex scandal with alleged police cover-up.
Guildford Four & Birmingham Six cases: Wrongful convictions in 1970s–80s based on fabricated evidence.
Stephen Lawrence murder case (1993): Scotland Yard was criticized for racism and mishandling of investigation.
Judicial Relevance / Case Law Connection
While “Scotland Yard” itself is UK-based, Indian courts sometimes refer to its functioning while discussing police accountability and transparency.
For example:
In D.K. Basu v. State of West Bengal (1997), the Supreme Court of India emphasized safeguards against police abuse, drawing parallels with global concerns about misuse of police powers (similar to criticisms faced by Scotland Yard).
In Joginder Kumar v. State of U.P. (1994), the SC highlighted that “police are not above law,” reflecting lessons from international experiences including misconduct in agencies like Scotland Yard.
Conclusion
PC Act Ruling (SC): Delay in preliminary enquiry ≠ reason to quash corruption proceedings. Substance prevails over procedure.
Scotland Yard’s Dark Secrets: Symbolize both the prestige of detective policing and the dangers of secrecy, misconduct, and abuse of power. Courts worldwide (including India) use such lessons to ensure police accountability and protection of fundamental rights.
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