The Supreme Court quashed an FIR alleging offences under Sections 60(b), 316(2), and 318(2) of the Bharatiya Nyaya Sanhita, 2023, holding that the dispute was purely civil in nature. The Court reiterated that criminal proceedings cannot be used to enforce monetary claims and emphasized that cheating requires dishonest intent from inception. Criticizing the High Court’s mediation order directing upfront payment, the SC ruled that such disputes must be resolved through civil remedies, not criminal prosecution. The judgment reaffirmed the principles laid down in State of Haryana v. Bhajan Lal and Delhi Race Club (1940) Ltd. v. State of Uttar Pradesh to prevent abuse of criminal law in commercial disputes.
Facts Of The Case:
The case involves a criminal appeal filed by Shatlesh Kumar Singh, a co-founder of Karma Media and Entertainment LLP, against an FIR lodged by Respondent No. 4 (M/s Polaroid Media) under Sections 60(b), 316(2), and 318(2) of the Bharatiya Nyaya Sanhita (BNS), 2023, alleging cheating, criminal breach of trust, and concealment of design to commit an offence. The dispute arose from a commercial transaction where Polaroid Media claimed financial losses due to an alleged oral agreement with Singh’s company. The Allahabad High Court, instead of quashing the FIR, directed the parties to mediation and ordered Singh to pay Rs. 25 lakhs to the complainant as a precondition.The Supreme Court overturned the High Court’s order, holding that the FIR disclosed no prima facie criminal offence and that the dispute was purely civil in nature. The Court emphasized that criminal proceedings cannot be used to recover debts or resolve contractual disagreements. It criticized the High Court for imposing a monetary condition before mediation, stating that such an approach was unjustified in a writ petition seeking quashing of an FIR. The SC clarified that cheating requires dishonest intent from the inception, which was absent in this case, and advised the complainant to pursue civil remedies instead of criminal prosecution. The FIR was quashed, upholding the principle that criminal law should not be misused for settling financial disputes.
Procedural History:
The case originated with the filing of an FIR by Respondent No. 4 (M/s Polaroid Media) against the appellant (Shatlesh Kumar Singh) under Sections 60(b), 316(2), and 318(2) of the Bharatiya Nyaya Sanhita, 2023, at Hariparwat Police Station, Agra. The appellant approached the Allahabad High Court under Article 226 of the Constitution seeking quashing of the FIR, arguing it was a misuse of criminal process to enforce a civil dispute. The High Court, instead of adjudicating on the merits, directed the parties to mediation and ordered the appellant to pay Rs. 25 lakhs to the complainant as a precondition for mediation, while granting interim protection from arrest.Dissatisfied with this order, the appellant filed a Special Leave Petition before the Supreme Court, which granted leave and heard the appeal. The Supreme Court scrutinized the FIR and found no prima facie evidence of criminal offences, observing that the dispute was purely civil in nature. It criticized the High Court’s unusual directive for upfront payment before mediation, noting such conditions were inappropriate in a quashing petition. Ultimately, the Supreme Court allowed the appeal, quashed the FIR, and clarified that the complainant must pursue civil remedies if seeking monetary recovery, thereby concluding the litigation in favor of the appellant.
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Court Observation:
The Supreme Court made several critical observations while adjudicating this case. It firmly reiterated that criminal proceedings cannot be used as a tool for debt recovery or to resolve purely civil disputes, emphasizing this constitutes an abuse of the legal process. The Court noted that for an offence of cheating under Section 318(2) BNS to be established, there must be clear evidence of dishonest intent from the very inception of the transaction, which was conspicuously absent in the present case. The Bench expressed strong disapproval of the High Court’s approach in directing upfront payment of Rs. 25 lakhs as a precondition for mediation, observing that such orders effectively prejudge the merits of the dispute and unfairly burden the accused. It highlighted that mediation should be voluntary and not imposed through coercive conditions, especially in petitions seeking quashing of FIRs. The judgment underscored that High Courts must examine the prima facie validity of FIRs based on established parameters from State of Haryana v. Bhajan Lal, rather than adopting unconventional approaches that compromise legal principles. Additionally, the Court clarified that disputes arising from commercial transactions or alleged breach of contractual terms should be adjudicated through civil remedies, not criminal prosecution. It warned against the growing trend of converting civil disputes into criminal cases, noting this practice clogs the criminal justice system and causes unnecessary harassment. The observations reaffirmed the judiciary’s role in preventing misuse of criminal law while protecting citizens from frivolous litigation.
Final Decision & Judgement:
The Supreme Court allowed the criminal appeal and quashed the FIR registered against the appellant under Sections 60(b), 316(2) and 318(2) of the Bharatiya Nyaya Sanhita, 2023. The Court held that the allegations in the FIR disclosed no prima facie criminal offense and that the dispute was purely civil and commercial in nature, arising from an alleged oral agreement between the parties. Criticizing the High Court’s approach, the Supreme Court set aside the order directing the appellant to pay ₹25 lakhs as a precondition for mediation, observing that such directions were inappropriate in a petition seeking quashing of criminal proceedings. The judgment reaffirmed the principle that criminal law cannot be used as a shortcut for recovery of alleged dues, which should properly be adjudicated through civil remedies. While quashing the FIR, the Court clarified that its decision would not preclude the complainant from pursuing appropriate civil remedies for recovery of any alleged dues. The judgment serves as an important reminder of the judiciary’s role in preventing misuse of criminal proceedings in commercial disputes.
Case Details:
Case Title: Shatlesh Kumar Singh @ Shatlesh R. Singh vs. State of Uttar Pradesh & Ors. Citation: 2025 INSC 869 Criminal Appeal No.: Criminal Appeal No. 2963 of 2025 Date of Judgment: 14th July 2025 Judges/Justice Name: Justice J.B. Pardiwala & Justice R. Mahadevan
Download The Judgement Here