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M.N.G Bharateesh Reddy vs Ramesh Ranganathan and Another

Criminal Appeal · 2022 INSC 847Decided 18 Aug 2022
Criminal Appeal No. 1273 of 2022
Dr Dhananjaya Y Chandrachud · A.S. Bopanna

Background

The first respondent worked as a Consultant Neurosurgeon at BGS Apollo Hospital, Mysore, under a Consultancy Agreement allowing termination by either side on 30 days' notice. After a pay dispute and complaints about patient referrals and billing irregularities, the hospital terminated his services in May 2014. He filed a criminal complaint against the appellant (the hospital's General Manager) alleging cheating, criminal breach of trust, and defamation. The trial court took cognizance of several IPC offences; the Sessions Judge quashed that order, but the Karnataka High Court partly restored it, holding that offences under Sections 405 and 420 IPC were prima facie made out.

Decision Breakdown

The Supreme Court examined the complaint's own averments against the settled legal ingredients of cheating (Sections 415/420 IPC) and criminal breach of trust (Section 405 IPC), relying on precedents including Hridaya Ranjan Prasad Verma and Dalip Kaur. It held that a mere breach of contract does not become a criminal offence unless fraudulent or dishonest intent existed from the very inception of the dealing, and criminal breach of trust additionally requires clear proof of "entrustment" of property. The complaint disclosed, at most, disputes over billing and termination under a commercial consultancy contract, a civil dispute, with no averment of deception, inducement to part with property, or entrustment. Finding the High Court erred in restoring cognizance under Sections 405, 415 and 420 IPC, the Supreme Court allowed the appeal, set aside the High Court's judgment, and restored the Sessions Judge's order quashing the criminal proceedings.

Lesson Learnt

A commercial or employment dispute (such as a disagreement over fees, billing, or termination of a contract) cannot be dressed up as a criminal case of cheating or breach of trust unless the complaint itself shows fraudulent intent from the outset and (for breach of trust) actual entrustment of property; courts will quash criminal proceedings that are really a civil dispute in disguise.

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

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