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Anand Kumar @ Sanjay Lalwani v. The State of Madhya Pradesh

Criminal Appeal · 2026 INSC 928Decided 31 Aug 2026
Crl.A. No.-004110-004110 - 2026 (arising from SLP(Crl) No.19051/2025)
Justice K.V. Viswanathan · Justice Arun Palli

Background

A criminal complaint accused the appellant of forging a Power of Attorney purportedly executed by one Pradeep Singh Mehta, and using it to fraudulently form a partnership and get Mehta's 54.48-acre land mutated in the partnership's name. The complaint, however, was filed not by Mehta himself but by his cousin, Subhash Chandra Lalwani, who separately claimed 7.5 acres of that land had earlier been given to him. Years later, Mehta filed an affidavit saying he had no grievance against the appellant and wished the case to end, but the complainant refused to settle. The High Court declined to quash the case since the complainant was not a party to the compromise.

Decision Breakdown

The Supreme Court held that a "victim" (the person who actually suffered loss) and an "informant" (the person who lodges a complaint) are legally distinct, and that for a criminal case to be quashed on the ground of settlement, it is the genuine victim's consent that matters, not necessarily the informant's. Since it was Mehta whose signature was allegedly forged and whose land was affected, he was the true victim, and he had validly settled. The complainant's own claim to the 7.5 acres was unsubstantiated by any documents and had already been doubted by an earlier High Court finding. Continuing the prosecution in these circumstances would be an abuse of process, so the proceedings were quashed.

Lesson Learnt

In criminal law, the person who files a complaint is not always the actual "victim" of the offence. When a case is being considered for quashing based on a settlement, what matters legally is the consent of the real victim who suffered the loss, not merely the person who set the criminal process in motion.

Official source (sci.gov.in)View Judgment (PDF)

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