The Supreme Court has quashed an FIR registered under the Uttar Pradesh Gangsters and Anti-Social Activities (Prevention) Act, 1986, holding that non-compliance with mandatory procedural requirements vitiates the very foundation of such proceedings.

The Bench, comprising Justices Sanjay Kumar and K. Vinod Chandran, focused primarily on whether the “Gang Chart”—a crucial document forming the basis of action under the Gangsters Act—had been prepared in accordance with the statutory framework and the Uttar Pradesh Gangsters and Anti-Social Activities (Prevention) Rules, 2021.

The judgment came in a criminal appeal filed by Gabbar Singh alias Devendra Pratap Singh, who had challenged the refusal of the High Court to quash an FIR lodged against him in Bahraich district of Uttar Pradesh. The FIR accused him of being a gang leader involved in multiple offences, including land grabbing, extortion, forgery, and criminal intimidation.

The Court noted glaring deficiencies in the Gang Chart that accompanied the FIR. It observed that the certified copy of the document, as received by the jurisdictional court, lacked essential elements such as signatures and recommendations from the competent authorities, including the Station House Officer, Additional Superintendent of Police, Superintendent of Police, and the District Magistrate. These endorsements are not mere formalities but mandatory requirements under the law.

Rejecting the State’s argument that the original Gang Chart contained proper approvals, the Court held that what matters is the validity of the document forming the basis of the FIR at the time of its registration. It emphasized that there was no evidence of a mandatory joint meeting between the District Magistrate and the Superintendent of Police, a critical procedural step required before approval of the Gang Chart.

The Bench reiterated the well-established legal principle that when a statute prescribes a particular method for performing an act, it must be done strictly in that manner or not at all. The Court underscored that such procedural safeguards are especially vital in laws like the Gangsters Act, which carry serious consequences, including stigmatization and deprivation of personal liberty.

“Liberty of an individual is precious and can be curtailed only in accordance with law,” the Court observed, cautioning against casual or mechanical invocation of stringent laws without strict adherence to prescribed procedures.

Accordingly, the Court set aside the High Court’s orders and quashed the FIR registered on May 28, 2022, at Kotwali Nagar Police Station in Bahraich. However, it clarified that its ruling was confined to procedural irregularities in the Gang Chart and would not affect the ongoing proceedings in other criminal cases registered against the appellant.

The Court also noted that the authorities are not barred from initiating fresh proceedings in accordance with law, provided all statutory requirements are duly complied with.

Case Details

Case Title: Gabbar Singh alias Devendra Pratap Singh Alias Rajesh Singh Versus State of U.P. and Ors.

Citation: JURISHOUR-457-SC-2026

Case No.: Special Leave Petition (Crl.) No.17929-17930 of 2025

Date: 20/03/2026

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