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Sardar Ali Khan v. The State of Uttar Pradesh

Criminal Appeal · 2020 INSC 90Decided 24 Jan 2020
Criminal Appeal No. 161 of 2020
Justice Mohan M. Shantanagoudar · Justice R. Subhash Reddy

Background

The appellant had purchased a plot of land through a registered sale deed in 1994 from the father of the second respondent. After the seller's death in 1997, his son (the second respondent) filed a civil suit in 2008 seeking cancellation of the sale deed, alleging it was obtained fraudulently. In 2012, four years after filing the civil suit, and nearly two decades after the sale deed itself, the second respondent also lodged a criminal complaint against the appellant (then about 87 years old) alleging forgery, cheating and impersonation. The Allahabad High Court refused to quash this criminal case, prompting the appeal to the Supreme Court.

Decision Breakdown

The Supreme Court held that pursuing parallel criminal proceedings over a dispute already pending before a civil court, with no allegation of impersonation or forged signatures and a long unexplained delay in filing the complaint, amounted to an abuse of the process of law. Since the validity of the sale deed was squarely before the civil court, the complainant could not use criminal proceedings to strengthen his civil case. The Court allowed the appeal, set aside the High Court's order, and quashed the criminal complaint and all consequential proceedings, while making clear the pending civil suits must still be decided independently on their own merits.

Lesson Learnt

A genuine civil property dispute cannot be converted into a criminal prosecution simply to add pressure on the other side; courts will quash criminal cases that are used as a backdoor route to relitigate issues already pending in a civil suit.

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

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