Meghalaya HC Quashes Case Against Ex-Education Minister Ampareen Lyngdoh Over 2008 Recruitment Scam

The Meghalaya High Court has quashed criminal proceedings against former Education Minister of Meghalaya, Ampareen Lyngdoh, former Director of Elementary and Mass Education, J.D. Sangma, and former Deputy Director, Ameka I. Lyngdoh, in connection with allegations of manipulation in the 2008 recruitment of assistant teachers in lower primary schools. The Court held that the prosecution had failed to establish even a prima facie case against the accused and that allowing the trial to continue would amount to an abuse of process.

Chief Justice I.P. Mukerji observed that the materials relied upon by the prosecution, including the alleged slips and score sheets, did not link the accused to any manipulation of results. Court noted that no document showing interpolation or any application of white ink for erasing the marks are on record, and further, that the slips allegedly furnished by the then minister did not suggest specific directions for altering marks.

The Court held that the evidence was so weak that even reasonable suspicion could not arise against the accused, thereby warranting discharge under Sections 227 and 482 of the Code of Criminal Procedure.

The case stemmed from allegations that during the 2008 recruitment process, the accused conspired to manipulate results to favour certain candidates. Following an FIR lodged in 2011, the matter was initially investigated by the State Police before being transferred to the CBI in 2017.

The CBI filed its chargesheet in June 2020, invoking Sections 120-B read with 420, 467, 468, 471 and 201 of the IPC.

However, charges were framed only in August 2022, after a prolonged delay. Out of over 500 candidates, the candidature of 246 was cancelled as allegedly tainted. The prosecution listed over 300 witnesses, later pruned to 181, of whom only 28 have been examined to date.

Senior Advocates Salman Khurshid and K. Paul, appearing for the accused, placed reliance on several Top Court decisions on the scope of discharge under Section 227 CrPC and the inherent powers of the High Court under Section 482.

The Court referred to Baliya @ Bal Kishan v. State of Madhya Pradesh (2012) 9 SCC 696, which emphasised that conspiracy is rarely proved by direct evidence and must be inferred only from cogent circumstances proved beyond reasonable doubt.

It also cited State of Tamil Nadu v. N. Suresh Rajan (2014) 11 SCC 709, which held that at the discharge stage, the Court must assume the prosecution’s material to be true but can sift evidence to see if it discloses the offence.

Further reliance was placed on Dipakbhai Jagdishchandra Patel v. State of Gujarat (2019) 16 SCC 547, which clarified that a strong suspicion backed by material evidence suffices to frame charges, but such suspicion must not be based merely on subjective satisfaction.

The Court also discussed Vikramjit Kakati v. State of Assam (2022) 17 SCC 249, which reaffirmed principles laid down in P. Vijayan v. State of Kerala (2010) 2 SCC 398 and M.E. Shivalingamurthy v. CBI (2020) 2 SCC 768, stressing that if two views are possible and only suspicion arises, discharge is warranted.

Applying these principles, Court found the prosecution case to be inconsequential. It was noted that all three levels of tabulation sheets bore identical contents and signatures of the same officials, undermining allegations of subsequent manipulation.

The alleged ministerial “slips” were unaccompanied by originals and lacked any clear nexus to result alteration.

In such circumstances, the Court concluded that the continuation of criminal proceedings after nearly 17 years would not only be futile but also a violation of the fundamental rights of the accused under Articles 14, 19 and 21 of the Constitution, given the mental agony caused by prolonged litigation.

It was emphasised that under Section 482 CrPC, it has a duty to prevent abuse of process and secure the ends of justice.

Observing that at the rate it is proceeding examination of all witnesses might take up the entirety of the remaining life of the accused, the Court held that the enormous delay coupled with weak evidence justified quashing. Accordingly, the order dated 23 August 2022 of the Special Judge (CBI), East Khasi Hills, Shillong, rejecting the discharge applications, was set aside. The charges and criminal proceedings against all three accused were quashed, and they were discharged.

Case Title: CBI v. Smti. M. Ampareen Lyngdoh & Ors.

Date of Judgment: September 4, 2025

Bench: Chief Justice I.P. Mukerji