Case Summary: Ramesh Kumar Jayaswal v. CBI (2025)

This case concerns the conviction and sentencing of Ramesh Kumar Jayaswal, a promoter-director of Abhijeet Infrastructure Pvt. Ltd. (AIPL), in the coal block allocation scam—one of the most significant white-collar crime cases in India’s recent legal history. The appellant sought suspension of conviction under Section 528 of the BNSS, 2023, arguing that he would suffer irreversible damage—especially corporate disqualification—if the conviction order was not stayed.

Title of the Case: Ramesh Kumar Jayaswal v. Central Bureau of Investigation

Court: High Court of Delhi

Citation: 2025: DHC: 6327

Bench: Justice Amit Sharma

Date of Judgment: 1st August 2025

Background of the Case

The appellant, Ramesh Kumar Jayaswal, along with his brother Manoj Kumar Jayaswal (A-1) and the company M/s AIPL (A-3), was convicted by the Special CBI Judge in the Coal Block Case (Case No. CBI-41/2020, FIR RC 221 2016 E002). The charges included:

• Criminal conspiracy under Section 120B IPC
• Cheating under Section 420 IPC
• Use of forged documents under Section 471 IPC

Sentence

On 11 December 2024, the Trial Court sentenced the appellant to:

• Three years of rigorous imprisonment for each offence (to run concurrently)
• Total fine of ₹20 lakhs, with a default clause of four months of simple imprisonment

Allegations Against the Appellant

The CBI accused the appellant of:

• Falsely representing himself as Director/Joint Managing Director of AIPL even after his resignation in 2002
• Submitting forged documents to the 24th Screening Committee of the Ministry of Coal and Ministry of Steel
• Misleading the authorities for securing allocation of Brinda and Sisai coal blocks
• The appellant allegedly participated in multiple Screening Committee meetings (18th, 21st, 22nd, and 24th in 2003) despite his non-affiliation with AIPL post-2002.

Appellant’s Arguments

Senior Advocate Siddharth Aggarwal, representing the appellant, raised several points:

1. No Role in Forgery

• The appellant separated from the family business in 2002 and formed the “Neco Group.”
• AIPL was entirely run by Manoj Kumar Jayaswal (A-1), who was responsible for all coal-related matters.
• The CBI and Trial Court findings themselves noted this business separation.

2. No Incriminating Evidence by Witnesses

• Key witnesses (PW-14 – A.K. Srivastava and PW-20) did not implicate the appellant.
• PW-14 confirmed that Manoj responded to queries before the 24th Screening Committee.
• PW-20 did not mention the appellant regarding any forgery or conspiracy.

3. Improper Trial Procedure

• The Trial Court allegedly considered records not presented during prosecution evidence, violating fair trial principles.
• These records were neither relied on during the charge framing nor put to the appellant under Section 313 BNSS.

4. Irreversible Consequences

The appellant is:

Managing Director of JNIL (Jayaswal Neco Industries Ltd.), a publicly listed company with:

• Over 9,500 employees
• ₹6,000 crore revenue
• ₹3,000 crore debt guaranteed personally by the appellant

If the conviction stands:

• Disqualification under Section 196(3)(d) of Companies Act, 2013 will apply
• Business operations and employment of thousands will suffer
• Public shareholders and lenders will face massive losses

He cited Afzal Ansari v. State of U.P. (2024) 2 SCC 187, to claim protection against “irreversible consequences”.

The appellant also relied on Rama Narang v. Ramesh Narang [(1995) 2 SCC 513] and Madhu Koda v. State through CBI [Delhi HC, 2024] in support of his arguments.

CBI’s Counterarguments

Senior Advocate R.S. Cheema, appearing for the CBI, strongly opposed the stay of conviction:

1. Public Interest and Gravity of Offence

• The case is part of the coal block scam, classified as a “unique category” by the Supreme Court in Girish Kumar Suneja v. CBI (2017) 14 SCC 809
• Massive misuse of political influence and fraud on the government necessitates stringent treatment

2. Evidence Against Appellant

• Attendance records showed that Ramesh Kumar Jayaswal attended the 24th Screening Committee as “Director” of AIPL
• Despite claiming resignation in 2002, he signed two letters in July and August 2003 as “Authorized Signatory” of AIPL
• These letters contained detailed technical justifications for coal block allocation

3. Deceptive Defence

• Ramesh claimed he signed as director of AIPL due to oversight, which the Trial Court rejected as evasive
• He never identified who actually represented AIPL during the Screening Committee, weakening his defence

4. Ongoing Trial in Another Coal Block Case

• The appellant and JNIL are accused in another coal scam case
• His omission of this fact in the present application amounted to concealment, disentitling him from discretionary relief

Legal Framework Examined

The Court analysed:

• Section 528 BNSS/ Section 482 of CrPC – Appellate court’s power to stay conviction pending appeal.
• Companies Act, 2013, Section 196(3)(d) – Disqualification upon conviction with a sentence over 6 months, irrespective of moral turpitude.

Observations of the Court

Justice Amit Sharma noted:

1. Merits Not Enough: The argument that the conviction is likely to be reversed on appeal is insufficient to warrant a stay.
2. Irreversible Consequences Not Made Out: Though JNIL is a major company, business setbacks—even substantial—do not equate to fundamental loss of rights like electoral disqualification.
3. Public Confidence: Suspending a conviction in a scam of national significance, involving misuse of public resources, would damage public trust in the legal process.
4. Comparative Cases Distinguishable: Afzal Ansari involved a sitting MP and had political disenfranchisement consequences. Jayaswal is not in public office.
5. No Clean Record: The appellant is facing other prosecutions in the same scam, undermining claims of clean antecedents.

Decision

The Court held that:

“The appellant has failed to make out a case for staying the operation of the impugned judgment of conviction. The public interest involved in coal allocation cases, coupled with clear findings on record regarding appellant’s misrepresentation, militates against the grant of such relief.”

The Court dismissed the application, holding that:

• The conviction was based on well-reasoned findings of the trial court, including evidence of active involvement and misrepresentation.
• Disqualification under the Companies Act is a legal consequence of conviction, not a punishment to be stayed unless truly exceptional.
• The case does not meet the high threshold of “irreversible consequences” as set out in Afzal Ansari or Rama Narang.

Thus, the stay on conviction was denied.

Conclusion

The Delhi High Court’s ruling in Ramesh Kumar Jayaswal v. CBI balances the individual’s claim of professional and economic loss with the broader public interest in combating white-collar crimes. The court emphasised that a stay of conviction is an exception, not the norm—especially in cases like the coal block scam, which has shaken institutional trust. The ruling stands as a warning to corporate leaders and public figures that positions of power come with heightened legal responsibility and consequences.

Click Here to Read the Official Judgment

Important Link

Law Library: Notes and Study Material for LLB, LLM, Judiciary, and Entrance Exams