The Supreme Court reiterated that criminal proceedings which are manifestly mala fide or constitute an abuse of the legal process are liable to be quashed under Section 482 of the Cr.P.C. It emphasized that criminal law cannot be invoked to settle purely civil disputes or for wreaking vengeance, applying the principles established in State of Haryana v. Bhajan Lal. The Court allowed the appeal and quashed the FIR and charge sheet.
Facts Of The Case:
The appellant, Anukul Singh, became embroiled in a criminal prosecution originating from a property dispute. His father had purchased a piece of land, and after objecting to the performance of Qurbani (animal sacrifice) on it, the appellant alleged harassment from local authorities and the Shaher Imam. Subsequently, eight FIRs were registered against him within a week, including the subject case, Crime No. 47 of 2003. This FIR was lodged by Respondent No. 2, who claimed he approached the appellant for a loan but was compelled to execute an agreement to sell for his plot and issue cheques that were later dishonoured. The appellant contended this FIR was a malicious counterblast to a prior case he had filed against the complainant. He sought quashing of the charge sheet, arguing the allegations disclosed only a civil dispute and that the prosecution was vitiated by mala fides and an ulterior motive to harass him, constituting a gross abuse of the legal process. The High Court dismissed his petition, leading to the present appeal before the Supreme Court.
Procedural History:
The procedural history of the case commenced with the registration of FIR No. 47 of 2003 at Police Station Bilari, leading to the filing of a charge sheet against the appellant. The appellant, seeking redress, filed an application under Section 482 of the Code of Criminal Procedure, 1973 before the High Court of Judicature at Allahabad, praying for the quashing of the charge sheet and the consequent criminal proceedings. The High Court, by its impugned judgment and final order dated 22.10.2019, dismissed the said application. Challenging this dismissal, the appellant preferred a Special Leave Petition (Crl.) No. 2682 of 2020 before the Supreme Court. Upon granting leave, the Special Leave Petition was converted into the present Criminal Appeal, which was ultimately allowed by the Supreme Court.
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Court Observation:
The Supreme Court observed that the allegations in the FIR, even if taken at face value, disclosed a dispute of a purely civil nature arising from a commercial transaction concerning a loan and an agreement to sell, and did not prima facie constitute the essential ingredients of the criminal offences of cheating or forgery. The Court found that the criminal proceeding was manifestly attended with mala fide and was maliciously instituted as a retaliatory counterblast to the legitimate proceedings previously initiated by the appellant, squarely falling within the categories illustratively laid down in State of Haryana v. Bhajan Lal. It was held that the continuation of such a prosecution, which was an obvious attempt to use criminal law as a tool for wreaking vengeance in a civil dispute, amounted to a gross abuse of the process of the court.
Final Decision & Judgement:
The Supreme Court allowed the criminal appeal and set aside the impugned judgment of the High Court. Consequently, FIR No. 47 of 2003 dated 05.02.2003, registered under Sections 420, 467, and 468 of the Indian Penal Code at Police Station Bilari, District Moradabad, and the consequential charge sheet dated 16.04.2003, along with all ensuing proceedings, were quashed. The Court, however, clarified that its judgment would not preclude the involved parties from pursuing any civil remedies that may be available to them in accordance with the law.
Case Details:
Case Title: Anukul Singh Versus State of Uttar Pradesh and Anr. Citation: 2025 INSC 1153 Criminal Appeal No.: Criminal Appeal No. 4250 of 2025 Date of Judgement: September 24, 2025 Judges/Justice Name: Justice R. Mahadevan and Justice B.V. Nagarathna
Download The Judgement Here