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Parag Kishore Satoskar and Others v. State of Jharkhand and Another

Criminal Appeal · 2026 INSC 846Decided 12 Aug 2026
Crl.A. No.-003803-003803 - 2026 (Arising out of SLP(Crl.) Nos. 3933 and 3996 of 2025)
Justice Sanjay Karol · Justice Augustine George Masih

Background

The complainant, a camphor wholesaler in Ranchi, was offered a three-year distributorship by Oriental Aromatics Limited and paid substantial advances against goods, only some of which were supplied. After the complainant questioned pricing, the company stopped supplies and the distributorship agreement was terminated within about a month and a half. He then filed an FIR against the company's directors and officers alleging cheating and criminal breach of trust, which the Jharkhand High Court declined to quash.

Decision Breakdown

The Supreme Court held that the FIR, even taken at face value, did not disclose the essential ingredients of either offence. For cheating, there was no averment that the company lacked intent to perform when the agreement was signed or when payments were received: the complaint showed goods were actually supplied and bills raised, meaning any wrongdoing (if any) arose only later, as a breach of contract rather than deception at inception. For criminal breach of trust, there was no entrustment alleged: money paid as advance for goods becomes the seller's own property under the contract, not property held in trust. The Court also noted the two offences are legally incompatible on the same facts, and that the complainant's own legal notices, sent soon after termination, never mentioned the unreturned advance that later became the centrepiece of the FIR. Both appeals were allowed and the FIR quashed.

Lesson Learnt

A civil or commercial dispute (such as a contract dispute over pricing, supply, or unreturned advances) cannot be converted into a criminal case unless the complaint specifically alleges dishonest intent that existed from the very beginning of the transaction; the proper remedy for such disputes is a civil claim for damages or recovery, not a police FIR.

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

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