Union of India v. Prafulla Kumar Samal (1979) 3 SCC 4:

While dealing with the stage of framing charges (Sections 227/228 CrPC), this landmark judgment established principles for evaluating prosecution material, stating that the Court is not to act as a mere post office and must determine if there is ‘sufficient ground for proceeding’. This underlying principle of assessing the prosecution’s case for its evidentiary value is crucial to understanding the ‘no evidence’ threshold in Section 232.

State of M.P. v. S.B. Johari (2000) 2 SCC 57:

Reiterating principles from Prafulla Kumar Samal, this case emphasized that at initial stages, the Court is not required to meticulously examine evidence but must determine if a prima facie case is made out from the prosecution records. An acquittal under Section 232 signifies that even this preliminary threshold of a prima facie case has not been met after the entire prosecution evidence has been presented.

Satish Mehra v. State of N.C.T. of Delhi (2012) 13 SCC 148:

Although pertaining to a Magistrate’s power to recall a witness, this judgment implicitly reinforces the judicial responsibility to ensure a trial proceeds only when some credible material exists. The ‘no evidence’ standard in Section 232 represents an absolute failure of the prosecution to meet even this basic evidentiary requirement, leading to a mandatory acquittal.