The Supreme Court on Wednesday quashed the 2015 order of a Special CBI Court summoning former Prime Minister Dr. Manmohan Singh in a coal block allocation case, holding that the trial court had no justification to reject the Central Bureau of Investigation's (CBI) closure report and take cognizance against him.

A Bench comprising Chief Justice of India Surya Kant, Justice Joymalya Bagchi and Justice V Mohana allowed Singh's appeal, accepted the CBI's closure reports giving him a clean chit, and closed the proceedings.

Although Dr. Singh passed away in December 2024, the Court decided to examine the legality of the trial court's order because it contained adverse observations against him.

Appearing for the late former Prime Minister, Senior Advocate Kapil Sibal submitted that while the appeal could have technically become infructuous after Singh's demise, the trial court's remarks warranted interference.

"One of the cases concerns Dr. Manmohan Singh," Sibal told the Bench. He urged the Court to expunge the observations made against the former Prime Minister.

The Chief Justice observed that the matter could be disposed of, to which 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, pointed out that issues relating to the vires of certain provisions survived in connected matters. Senior Advocate Abhishek Manu Singhvi submitted that, at least insofar as Dr. Manmohan Singh was concerned, the remarks could be effaced.

Allowing the appeal, the Bench noted that the Special Judge had taken cognizance under the Prevention of Corruption Act against six persons, including the former Prime Minister, despite the CBI filing 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 recorded.

The Court observed that although Singh's death meant that the appeal could have been disposed of as infructuous, it was necessary to examine the correctness of the Special Judge's decision to summon him.

"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," the Bench said.

The Court held that the Special Judge had failed to apply the settled principles governing acceptance of closure reports filed by investigating agencies.

"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.

Accordingly, the Supreme Court allowed the appeal, set aside the Special Judge's cognizance order, accepted the CBI's closure reports, and closed the matter.

The order came during a hearing of a batch of coal block allocation matters, where the Bench also considered whether certain issues still required adjudication by the Supreme Court or could be left to the High Courts. During the hearing, Sibal remarked, "Mood of the nation was different then. It's different today."

Case : Dr Manmohan Singh v. CBI | Crl Appeal 562-563/2015