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Shatrughna Atmaram Patil & Ors. vs. Vinod Dodhu Chaudhary & Anr.

Not available · 2024 INSC 75Decided 30 Jan 2024
Not available
Justice Vikram Nath · Justice Satish Chandra Sharma

Background

Two tenants (Vijaykumar Dhawale and Vinod Chaudhary) occupied premises whose owner later sold the property to five purchasers before allegedly dying by suicide, leaving a note naming the tenants as abettors. No FIR was registered against the tenants, but the very next day police detained the tenants for about 24 hours, during which the premises were demolished by the deceased owner's family with police support, and the tenants were allegedly forced to sign documents consenting to vacate. The tenants' criminal complaint under Section 156(3) CrPC against 13 accused (the owner's brother, widow, the five purchasers, and six police personnel) was eventually ordered to be registered and investigated, a decision upheld and expanded by the Bombay High Court, prompting the accused to approach the Supreme Court. During the pendency of these petitions, the purchasers paid the two tenants Rs. 10 lakh each in settlement, and the tenants agreed not to pursue their complaints.

Decision Breakdown

The Supreme Court held that with the tenants' losses compensated and their willingness to withdraw the complaints, continuing the proceedings against the private accused (owner's brother, widow, and purchasers) would serve no purpose and quashed those proceedings. However, the Court was not satisfied that the six police personnel (who appeared complicit in illegally detaining the tenants, coercing them to sign documents, and allowing an unauthorized demolition) should go free without consequence. It directed the police personnel (ranked from Constable to Inspector) to collectively pay Rs. 6 lakh in costs per complainant, calibrated by rank, to a specified welfare fund, with proceedings against them to be quashed only upon proof of payment; failing payment, their petitions would stand dismissed. The Court clarified that this cost order would not be treated as an adverse mark in their service records.

Lesson Learnt

A private settlement between complainant and accused can justify quashing criminal proceedings against private parties, but courts will not let police officials escape accountability for alleged abuse of power (illegal detention, coercion, and facilitating an unauthorized demolition) merely because the underlying dispute has been privately settled: accountability can be imposed even while closing the case.

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

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