The Supreme Court quashed criminal proceedings against Anukul Singh for offences under Sections 420, 467, and 468 IPC, finding them to be an abuse of process of law. The dispute originated from a land purchase by the appellant's father and subsequent objections by local religious authorities regarding Qurbani on the land. Respondent No. 2 filed an FIR alleging coercion in a loan transaction and agreement to sell, but the Court found these allegations disclosed only a civil dispute. The Court noted the FIR was a counterblast to earlier cases filed by the appellant, and the investigation was biased. Relying on precedents, the Court held that criminal proceedings should not be used to settle civil disputes and quashed the proceedings under Section 482 Cr.P.C.
Criminal Law-- Code of criminal Procedure, 1973-- Section 482-- Indian Penal Code, 1860-- Sections 42, 467 and 468-- Quashing-- Father of the appellant/accused purchased land-- Dispute-- Objections by opponent side-- Appellant implicated into eight FIRs within span of one week at the behest of local politicians and administration-- Aggrieved-- Application for quashing of criminal proceedings subsequent to criminal complaint filed before high court-- Dismissal of application by high court-- Aggrieved-- Inherent powers and jurisdiction u/s 482 of CRPC-- Case of Bhajan Lal (Supra) referred-- Jurisdiction, scope and ambit of Section 482 of CRPC referred and discussed-- Powers u/s 482 of CRPC must be exercised sparingly-- Civil nature of dispute relating to ownership and possession of property-- Prior to lodgment of complaint, appellant had already initiated proceedings against respondent no.2/complainant u/s 138 of NI Act in respect of dishonour of cheque-- Present complaint is a counter blast to the proceedings initiated by the appellant-- Case is fallen within the categories laid down in the case of Bhajan Lal (Supra)-- Continuation of proceedings amount to abuse of process of law-- Tendency to convert civil disputes into criminal proceedings deprecated-- No ingredients of forgery or cheating made out-- Complaint and consequent charge sheet quashed-- Appeal Allowed
Para-- 11, 11.1, 11.3, 11.5, 12, 14, 16, 17, 20
The Supreme Court allowed the criminal appeal, quashed the charge sheet dated 16.04.2003 and all consequential proceedings arising from Crime No. 47 of 2003
Citation: 2025 LawText (SC) (09) 32
Case Number: Criminal Appeal No. 4250 of 2025 (Arising out of SLP (Crl.) No. 2682 of 2020)
Date of Decision: 2025-09-24
Case Title: Whether the criminal proceedings initiated against the appellant under Sections 420, 467, and 468 of the Indian Penal Code, 1860 (IPC) should be quashed under Section 482 of the Code of Criminal Procedure, 1973 (Cr.P.C.) as being an abuse of process of law and disclosing only a civil dispute
Before Judge: B. V. NAGARATHNA J. , R. MAHADEVAN J.
Equivalent Citations: 2025 INSC 1153
Appellant: Anukul Singh
Respondent: State of Uttar Pradesh and Anr.
Nature of Litigation: Criminal appeal against dismissal of application under Section 482 Cr.P.C. seeking quashing of charge sheet and proceedings
Remedy Sought: Appellant sought quashing of criminal proceedings under Sections 420, 467, and 468 IPC
Filing Reason: Appellant alleged FIR was false, malicious, and disclosed only a civil dispute, filed as counterblast to earlier cases
Previous Decisions: High Court dismissed application under Section 482 Cr.P.C. on 22.10.2019; earlier interim stay granted on 22.05.2004
Issues: Whether the criminal proceedings should be quashed under Section 482 Cr.P.C. as abuse of process Whether the allegations disclose criminal offences or only a civil dispute
Submissions/Arguments: FIR and charge sheet disclose civil dispute, not criminal offences FIR was counterblast to earlier FIR No. 120/2002 filed by appellant Investigation was biased and conducted at behest of local politicians Defence material of unimpeachable character can be examined in Section 482 proceedings
Ratio Decidendi: Criminal proceedings under Sections 420, 467, and 468 IPC were quashed as they disclosed only a civil dispute regarding loan and agreement to sell, constituting abuse of process of law; the FIR was a counterblast to earlier cases, and such proceedings should not be used to settle civil disputes
Judgment Excerpts: The FIR dated 05.02.2003 and charge sheet dated 16.04.2003 are a gross abuse of the process of law Even if the allegations in the FIR are taken at their face value, they disclose at best a civil dispute The present FIR was lodged maliciously in connivance with the local police to wreak vengeance on the appellant
Procedural History: FIR registered on 05.02.2003 -- Charge sheet filed on 16.04.2003 -- Application under Section 482 Cr.P.C. filed in 2004 -- High Court granted interim stay on 22.05.2004 -- High Court dismissed application on 22.10.2019 -- Supreme Court appeal filed and allowed
