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Krishna Lal Chawla & Ors. v. State of U.P. & Anr.

Criminal Appeal · 2021 INSC 160Decided 8 Mar 2021
Criminal Appeal No. 283 of 2021
Justice Mohan M. Shantanagoudar · Justice R. Subhash Reddy

Background

Neighbours Krishna Lal Chawla and his family, and a man referred to as Respondent No. 2, had a physical altercation in 2012 and filed cross non-cognizable reports against each other. Years later, after the appellants' NCR led to a charge sheet being filed against Respondent No. 2 in 2017, Respondent No. 2 filed a fresh private complaint in 2018, nearly six years after the incident, making materially exaggerated and new allegations about the very same 2012 incident, without disclosing that a charge sheet already existed against him. A magistrate issued summons on this private complaint, and the Sessions Court and High Court upheld it, prompting the appellants to approach the Supreme Court.

Decision Breakdown

The Supreme Court held that filing a second, materially embellished complaint about the same incident against the same accused, after an earlier complaint had already led to investigation and a charge sheet, amounts to abuse of the process of court, relying on its precedents in Upkar Singh, T.T. Antony and Amitbhai Anilchandra Shah. It found Respondent No. 2's conduct in concealing the existing charge sheet and filing a delayed, inflated private complaint six years later to be mala fide and vexatious, violating the appellants' Article 21 right against being repeatedly dragged through frivolous litigation. The Court used its extraordinary power under Article 142 to quash not just the impugned private complaint but all connected litigation between the parties arising from the 2012 incident, and also delivered a broader exposition on the duty of trial magistrates to screen out frivolous criminal complaints at the threshold rather than mechanically issuing summons.

Lesson Learnt

Courts will not allow a complainant to file a fresh, exaggerated private complaint about an old incident as a "counter-blast" once an earlier complaint on the same facts has already been investigated: magistrates are expected to scrutinise private complaints carefully before summoning anyone, and the Supreme Court can use its Article 142 powers to end such cycles of retaliatory litigation altogether.

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

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