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Sardar Ravi Inder Singh & Anr. vs State of Jharkhand & Anr.

Not available · 2024 INSC 472Decided 8 Jul 2024
Not available
Justice Abhay S. Oka · Justice Ujjal Bhuyan

Background

The appellants, trustees of a private trust, had entered into agreements to sell property to the second respondent and his brother, acting through a partnership firm. The brother later informed the civil court (in the pending suit for specific performance) that the entire advance amount plus additional money had already been refunded, and sought to withdraw the suit, which the court permitted. Sometime later, the second respondent filed a criminal complaint against the appellants alleging cheating and criminal breach of trust over the very same sale transaction, even though he had not challenged the earlier withdrawal order and had, in a subsequent application, stated he would not claim any right over the property under an out-of-court settlement.

Decision Breakdown

The Supreme Court held that once the second respondent had unequivocally given up his claim to the property under a settlement, a statement he never disputed or challenged, continuing the criminal complaint over the same transaction amounted to abuse of the process of law. The High Court had wrongly refused to quash the complaint, partly by mistakenly treating the plea as barred under Section 362 CrPC (which bars a court from altering its own signed judgment), which did not apply to the separate prayer for quashing the complaint itself. The Supreme Court quashed the criminal complaint and allowed the appeal.

Lesson Learnt

A criminal complaint cannot be used as a tool to reopen or pressure over a civil/commercial dispute that a person has already settled and abandoned in open court, continuing such a complaint after giving up the underlying civil claim is treated as abuse of the legal process and will be quashed.

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

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