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Pramod Kumar Shukla v. State of Uttar Pradesh

Criminal Appeal · 2026 INSC 887Decided 19 Aug 2026
Criminal Appeal No. 3931 of 2026 (arising out of SLP (Criminal) No. 12908 of 2025)
Justice Prashant Kumar Mishra · Justice N.V. Anjaria · Justice Shree Chandrashekhar

Background

The complainant alleged that the appellant, claiming influence in the Directorate of Education, promised to secure clerical job appointments for his son and grandson in exchange for Rs. 20,00,000, of which the complainant paid several installments totaling Rs. 1,75,000 by bank transfer. When no interview or appointment materialised and the complainant sought his money back, he alleged the appellant abused and threatened him. The complainant had earlier tried to get an FIR registered through a court application under Section 156(3) CrPC, which was rejected because a police report suggested the dispute was actually about a land transaction; only later was a fresh FIR registered directly by police, this time citing additional material including an audio recording and allegedly forged admit cards and result documents.

Decision Breakdown

The Supreme Court held that the earlier rejection of the Section 156(3) application did not bar the police from later registering an FIR based on fresh material not previously placed before the Magistrate, and that the two situations involve legally distinct questions. Applying the well-established test from State of Haryana v. Bhajan Lal, the Court held that a court examining whether to quash an FIR must take the allegations at face value without assessing their truth, and found that the FIR here - alleging inducement of money through false promises, receipt of funds in the appellant's own bank account, forged documents, and threats - clearly disclosed cognizable offences requiring investigation, especially given the appellant faced five other similar FIRs. The appeal was dismissed and the FIR was allowed to proceed.

Lesson Learnt

An earlier rejection of a private application asking a magistrate to order police to register an FIR does not permanently block a later, separately-registered FIR if it is based on new evidence; and at the stage of deciding whether to quash a criminal case, courts will not weigh which side's version is more believable - that is left for trial.

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

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