Bombay High Court quashed charges against accused in 2006 Malegaon blast case, ending proceedings. Bench led by Shree Chandrashekhar and Shyam Chandak examined legality of trial court order.
The Bombay High Court quashed a special court’s order that had framed charges against four accused in the 2006 Malegaon blast case, effectively ending the criminal case against them.
A division bench of Chief Justice Shree Chandrashekhar and Justice Shyam Chandak allowed appeals filed by the accused against the trial court’s September 2025 order. While deciding, the High Court examined not only whether the charges were legally justified, but also how the trial court had framed them. It also scrutinised the trial court’s decision to discharge several co-accused in the same matter.
Factual Backgrounds:
The dispute traces back to the serial blasts on September 8, 2006, in Malegaon, a powerloom town in Maharashtra, during the holy month of Ramzan. Explosions near a mosque and a cemetery resulted in multiple deaths and left many people injured.
The incident led to widespread public outrage and intensified concerns of communal targeting. Initially, police registered offences under provisions of the Indian Penal Code, the Unlawful Activities (Prevention) Act, and other relevant laws against unknown persons. The first investigation was carried out by the Maharashtra Anti-Terrorism Squad (ATS), which arrested 12 persons and filed a chargesheet in December 2006.
Thereafter, the investigation was transferred multiple times between agencies. In February 2007, the case was handed over to the Central Bureau of Investigation (CBI). The probe was later moved to the National Investigation Agency (NIA), which carried out further investigation and submitted a supplementary chargesheet. During this stage, the NIA included the present appellants Rajendra Chaudhary, Dhan Singh, Manohar Ram Singh Narwaria, and Lokesh Sharma among the accused.
In September 2025, the special court framed charges against these four individuals. They challenged the order before the High Court by filing an appeal under Section 21 of the NIA Act, which provides a statutory right to challenge such orders.
Proceeding before the High Court:
Although the appeal was filed 49 days late, the High Court condoned the delay, taking into account the nature of the remedy provided by law. In January 2026, the High Court had already indicated that a prima facie ground for interference existed and had stayed further trial proceedings until the appeal was finally decided.
Before the High Court, the appellants raised multiple objections. They argued that the NIA did not present any direct eyewitness evidence linking them to the incident. They also contended that the trial court erred in framing charges without sufficient material. Further, they maintained that the discharge of certain co-accused could not be sustained legally, and noted that separate appeals against those discharge decisions were still pending raising concerns about consistency in the prosecution’s approach.
After reviewing the submissions, the High Court allowed the appeals and discharged all four accused, thereby bringing the proceedings against them to an end. The decision highlights the importance of close judicial scrutiny at the stage of framing charges, especially in grave cases involving allegations of terrorism. It also reflects the courts’ responsibility to ensure that prosecutions are supported by credible evidence and that individuals should not face prolonged trials in the absence of a prima facie case.
The judgment is an important development in the long-pending Malegaon blast case, which has undergone numerous investigative shifts and legal challenges over the years. It also underscores the difficulties of terror-related investigations and the need for procedural fairness particularly in cases that are transferred across different investigative agencies and evolve over time.
CASE TITLE: Rajendra Chaudhary & Ors. v. Union of India & Ors.
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