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Lilly Goyal v. State of Himachal Pradesh

Criminal Appeal · 2026 INSC 856Decided 11 Aug 2026
Criminal Appeal No. 3807 of 2026 (arising out of SLP (Crl.) No.12581 of 2026)
Justice J.B. Pardiwala · Justice K. Vinod Chandran

Background

The appellant, sister-in-law of a deceased man, had been embroiled in a bitter family dispute with her brother's widow (the second respondent) even before his death, with both sides filing complaints against each other. After the husband died, the two families settled most of their disputes through a settlement deed in June 2024, but one complaint under Section 182 IPC (giving false information to a public servant) filed against the appellant survived. The appellant sought to have this complaint quashed, but the Himachal Pradesh High Court refused, reasoning that offences under Section 182 IPC concern the public servant and the state, not private parties, so a private settlement could not end the case.

Decision Breakdown

The Supreme Court found that the High Court had rejected the quashing plea without actually examining the complaint itself. On scrutiny, the Court found that the second respondent's own complaint had been filed by her to the Women Police Station, not by any public servant to whom the allegedly false statements were addressed. Section 195 CrPC bars a court from taking cognizance of Section 182 IPC offences unless the complaint is filed by the public servant concerned (or their administrative superior) - and no such public servant had complained here. The Court held the proceedings were ill-motivated and legally unsustainable from the outset, quashed the case in its entirety, and directed that any bail bonds stand cancelled.

Lesson Learnt

A criminal complaint alleging that someone made false statements to government departments (Section 182 IPC) can only be validly prosecuted if it is filed by the public servant who was actually misled, or their superior - a complaint from an unrelated party, even a police station, does not meet this legal requirement and can be quashed on that ground alone.

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

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