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Senior Manager (P&D), RIICO Ltd. v. The State of Rajasthan and Anr.

Criminal Appeal · 2017 INSC 1074Decided 3 Nov 2017
Criminal Appeal No. 1845 of 2017
Justice A.K. Sikri · Justice Ashok Bhushan

Background

The appellant, a Regional Manager at RIICO Ltd., lodged a 1992 FIR under Section 420 IPC alleging that Respondent No. 2 (a company and its partner, Ravi Setia) had forged a letter purportedly issued by his own office and used it in a pending civil suit. A police Final Report concluded there was insufficient material to prosecute, and the appellant's challenges to that outcome were rejected first by a Chief Judicial Magistrate, then by a Revisional Court, and then by the Rajasthan High Court, each finding no sufficient evidence that the respondent had actually forged the letter. A forensic science laboratory report had found certain signatures to be forged but could not establish whose forgery it was, leaving the key allegation unproven.

Decision Breakdown

The Supreme Court reviewed the concurrent findings of the Magistrate, the Revisional Court, and the High Court, all of which had found no material on record to show that Respondent No. 2 had prepared or used a forged letter: the FSL report itself left open who, if anyone, had actually forged the disputed signatures. The Court also noted that an earlier procedural objection based on Section 195(1)(b)(ii) CrPC (which restricts prosecution for certain offences relating to documents produced in court without a complaint from the court itself) had already been examined and rejected by the Revisional Court, with the matter sent back for a decision purely on the evidence. Finding no infirmity in the High Court's view and no merit in the appeal, the Supreme Court dismissed it, upholding the refusal to prosecute Respondent No. 2.

Lesson Learnt

Filing an FIR alone does not guarantee prosecution: if investigation and repeated judicial review (through the Magistrate, Sessions Court, and High Court) all independently conclude the evidence doesn't actually support the forgery/cheating allegation, the Supreme Court will not reopen those concurrent factual findings just because the original complainant keeps appealing.

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

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