SC closes coal allocation case against former PM Manmohan Singh, clears him on merits

The Supreme Court on Wednesday closed the coal block allocation case against former prime minister Manmohan Singh, posthumously clearing him of corruption charges and holding that there was no sufficient material to prosecute him in connection with the allocation of the Talabira-II coal block in Odisha.

A three-judge Bench headed by Chief Justice of India Surya Kant set aside the trial court's order rejecting two closure reports filed by the Central Bureau of Investigation (CBI) in 2014, observing that there was no compelling reason to disregard the agency's findings.

The court said it would ordinarily have dismissed the appeal as infructuous following Singh's death in December 2024. However, it decided to examine the case on merits after reviewing the CBI's closure reports.

"We find no compelling reason for the Special Judge to have turned down the closure reports by the CBI and take cognisance of the case," the Bench observed in a brief order.

It added that there was no "sufficient material or good reason" to register a corruption case against the former prime minister.

The apex court allowed Singh's appeal, set aside the trial court's order and formally closed the case on merits.

Trial court had rejected CBI closure reports

Senior advocates Kapil Sibal and A.M. Singhvi, appearing for Singh, told the court that the CBI had filed closure reports on August 27 and October 21, 2014, concluding there was no case against the former prime minister.

Despite this, the Special Court rejected the reports, took cognisance of the case and summoned Singh as an accused on March 11, 2015.

The defence argued that the trial court proceeded against Singh without waiting for the mandatory sanction required to prosecute a public servant.

The Supreme Court accepted the appeal and held that the Special Court ought not to have rejected the CBI's conclusions.

Case related to Talabira-II coal block

The case arose from the 2005 allocation of the Talabira-II coal block in Odisha.

In 2015, the Special Court had summoned Singh, industrialist Kumar Mangalam Birla, former coal secretary P.C. Parakh and three others on charges including criminal conspiracy, criminal breach of trust by a public servant and offences under the Prevention of Corruption Act.

The Supreme Court subsequently stayed the summons.

Singh had consistently denied any wrongdoing and challenged the prosecution, arguing that the allocation decision involved no criminality and that the legal requirement for prior sanction to prosecute him had not been fulfilled.

The former prime minister died in December 2024. With Wednesday's ruling, the Supreme Court has brought the proceedings against him to a close, while setting aside the adverse observations made by the trial court.