Article 142 Explained: Why Supreme Court Quashed NEET Protest FIRs

The Supreme Court has invoked Article 142 of the Constitution to quash FIRs arising from student protests over the NEET-UG 2026 paper leak issue. The Court closed proceedings arising from protests held between July 20 and 25, while allowing Delhi Police to pursue one FIR against 2,873 people identified in its application, with their alleged roles in offences involving bodily harm or destruction of property to be investigated.

The order is significant because Article 142 gives the Supreme Court a power that other courts do not have in the same form: it can pass an order it considers necessary to do “complete justice” in a matter before it. The provision gives the Court flexibility to shape the relief it grants according to the facts of a case.

However, it is not an unlimited power to disregard laws or set aside statutory provisions. In the NEET protest case, the Court used Article 142 to direct that FIRs arising from the specified incidents across states and Union Territories should not be pursued or investigated, while keeping the door open for investigation into allegations of serious criminal conduct.

What Is Article 142 And How Does It Work?

Article 142(1) of the Constitution says that the Supreme Court may pass any decree or make any order necessary to do “complete justice” in any cause or matter pending before it. Such orders are enforceable throughout India.

Put simply, Article 142 gives the Supreme Court additional room to decide what remedy is needed to bring a case to a just conclusion. It allows the Court to mould relief according to the circumstances before it rather than being limited to a particular form of remedy.

The provision is, however, not a free pass for the Supreme Court to override the law.

The Court has repeatedly held that Article 142 cannot be used to disregard substantive law. It can be used to mould relief where necessary to achieve complete justice, but it cannot ordinarily be used to defeat an express statutory prohibition.

This distinction is important because Article 142 comes directly from the Constitution. It is not an ordinary provision in a statute that Parliament can apply through legislation. It is a constitutional power vested specifically in the Supreme Court.

The Court has also clarified that the expression “complete justice” has to be understood in the context of the case before it. Article 142 is not intended to create a general power that can be applied in the same way to every dispute.

The Supreme Court has previously held that Article 142 allows it to mould relief according to the circumstances of a case, while remaining within constitutional and legal limits.

The Supreme Court has also invoked Article 142 in cases involving criminal proceedings, but the existence of the power does not mean that every FIR can be quashed under it; the Court must consider the facts and circumstances of the case before it.

Article 142 is therefore best understood as a constitutional power to ensure complete justice in a matter before the Supreme Court. Its breadth gives the Court flexibility, but that flexibility does not place it above the law.

Why Did The SC Use Article 142 In The NEET Protest Case?

The case before the Supreme Court concerned FIRs registered in connection with student protests held between July 20 and 25 over the NEET-UG controversy.

The Centre, through Delhi Police, and the governments of Maharashtra, Assam, Bihar and West Bengal approached the Supreme Court seeking relief in connection with the FIRs. The Centre told the Court that the FIRs arising from the specified protest incidents would not be pursued and that no fresh FIRs would be registered over those same incidents.

The Supreme Court then used Article 142 to give effect to that position.

The Court quashed the FIRs specifically mentioned in the applications. It also directed that any other FIRs relating to the same protest incidents between July 20 and 25, in any state or Union Territory but not formally placed before it, should not be pursued or investigated and should be treated as closed. It further directed that no fresh FIR should be registered in connection with those same protest incidents.

Ordinarily, criminal proceedings are dealt with through the relevant courts and legal procedures. If similar FIRs are registered in different jurisdictions, those affected may have to seek relief through separate proceedings.

Here, the Supreme Court was dealing with FIRs arising from the same set of incidents. Article 142 allowed it to fashion a wider remedy covering those related proceedings instead of limiting the relief to the FIRs formally before it.

The Court also distinguished between participation in the protests and allegations of specific criminal acts.

Delhi Police had sought permission to register a fresh FIR concerning 2,873 people whom it identified in its application. According to Delhi Police's application, the 2,873 people were allegedly found to have serious criminal antecedents as per the NCRB database and were prima facie reported to be present at the protest site. The proposed investigation concerned allegations including bodily harm and destruction of property.

The Supreme Court allowed Delhi Police to pursue the fresh FIR concerning those 2,873 people.

This does not mean that the Court found those people guilty of any offence. The police allegations and their criminal antecedents are matters for investigation and, where appropriate, further legal proceedings. The Court's order allows the authorities to investigate the alleged criminal conduct; it does not amount to a finding of guilt.

This distinction also explains the limits of the relief granted to protesters. The Court did not create a blanket exemption from criminal law for everyone who attended the demonstrations. Rather, it closed the FIRs arising from the specified incidents while allowing the authorities to pursue allegations of serious criminal conduct involving the individuals identified in the application.

The Court also made clear that its decision was based on the peculiar facts and circumstances of the case and should not be treated as a precedent.

The order therefore does not establish a general rule that FIRs against protesters can be quashed under Article 142. Instead, it shows how the Supreme Court can use the provision to bring related proceedings arising from the same incidents to an end, while allowing investigation into specific allegations of serious criminal conduct.