The case stemmed from an incident at a resort owned by Accused No.1, who, along with other accused, was charged for involvement in a narcotics-related music festival held in May 2019. The appellant in this case, identified as Accused No.13, was accused of consuming narcotic substances during the event. His involvement in the case was largely based on the confession of another accused, Accused No.1.

The appellant, however, argued that the only material against him was the confession of a co-accused, which by itself was insufficient to justify framing charges against him. No physical evidence, such as the recovery of contraband from the appellant, was presented. Furthermore, the appellant had not undergone a medical examination to establish his consumption of narcotic substances.

The Supreme Court addressed the key issue of whether the confession of a co-accused could suffice to frame a charge against the appellant. Relying on established legal precedents, the Court reiterated that the confession of a co-accused cannot be the sole basis for framing charges, as it is inadmissible under Section 25 of the Indian Evidence Act. In the absence of corroborative evidence, such a confession could not be used to establish the appellant’s guilt.

The Court further referred to the scope of powers under Section 227 of the Criminal Procedure Code (Cr.P.C.), which allows a judge to discharge an accused if there is no sufficient ground to proceed with the trial. The Court underscored that at the stage of framing charges, the judge is required to sift through the evidence presented and determine whether there exists a prima facie case to proceed to trial.

The principles established in previous rulings, such as P. Vijayan v. State of Kerala and Suresh Budharmal Kalani v. State of Maharashtra, were cited. The Court clarified that it is not the judge's role to conduct a full trial at this stage but to determine whether the evidence presented can potentially lead to a conviction. If the evidence only raises suspicion, not grave suspicion, the judge has the discretion to discharge the accused.

In the case at hand, the Supreme Court found that the only material against the appellant was the inadmissible confession of the co-accused, and there was no other substantive evidence connecting him to the crime. As such, the Court concluded that the two lower courts erred in dismissing the appellant’s application for discharge. The Court emphasized that forcing the appellant to stand trial based on insufficient evidence would be a miscarriage of justice.

Accordingly, the Court set aside the High Court’s order and the order of the Additional District Judge, discharging the appellant from the case. The appeal was allowed, and the appellant was relieved from the proceedings of CC No.43 of 2020 pending before the Additional District Judge-Special Court under the Essential Commodities Act Cases in Coimbatore.

This ruling underscores the critical role of judicial discretion at the stage of framing charges and emphasizes that a judge must assess whether the available evidence is sufficient to proceed with a trial. The case highlights the importance of corroborative evidence and the inadmissibility of co-accused confessions under Indian law. In the absence of any concrete material linking the appellant to the crime, the Supreme Court’s decision provides a crucial reminder of the principle that no one should be made to stand trial unless there is a prima facie case against them.