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P. Vijay Nataraj & Ors. vs. State & Anr.

Criminal Appeal · 2022 INSC 906Decided 5 Sept 2022
Criminal Appeal No. 1448 of 2022
Uday Umesh Lalit · S. Ravindra Bhat

Background

The appellants had sold land to the complainant through two registered sale deeds, but the deeds did not disclose that the land was subject to a reservation under the Tamil Nadu Town and Country Planning Act, 1971 (it was earmarked for an inner ring road in the Coimbatore Master Plan). A criminal case was registered against the appellants on this basis, and their application for discharge was rejected by the trial court and, on revision, by the Sessions Judge, and finally by the Madras High Court. The appellants maintained they were themselves unaware of the reservation and had never claimed any continuing interest in the land after the sale.

Decision Breakdown

During the appeal, it emerged that the Madras High Court, in a separate writ petition filed by the appellants, had already declared the land released from the planning reservation under Section 38 of the Tamil Nadu Town and Country Planning Act and directed that it be handed over to the complainant (who had by then further transferred it to a fourth party). The appellants confirmed they stood by that order and had no claim to the land, and offered to refund the sale consideration if the complainant wished. The Supreme Court held that since the appellants never claimed any interest in the land and their bona fides were demonstrated by having secured the release order in the complainant's favour, the discharge application deserved to be allowed. It allowed the appeal, discharged the appellants of the criminal charges, and reaffirmed that the land stood released in favour of the complainant per the High Court's earlier order.

Lesson Learnt

A criminal prosecution over an alleged non-disclosure in a property sale can be resolved where the seller demonstrates good faith, by not contesting the buyer's rightful claim to the property and cooperating to resolve the underlying civil/planning dispute, showing that consistent, transparent conduct after a transaction can be decisive in securing discharge from criminal liability.

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

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