Skoda Auto Volkswagen India Private Limited v. The State of Uttar Pradesh
Background
Following the global "dieselgate" emissions scandal, Volkswagen group companies (later amalgamated into the petitioner) faced proceedings before the National Green Tribunal (NGT) over allegations that their diesel vehicles used software "defeat devices" to cheat emissions tests, resulting in a Rs 500 crore damages order against them: now under appeal before the Supreme Court. Separately, an individual car buyer who had purchased Audi vehicles filed a police complaint alleging he was duped into buying vehicles fitted with these cheat devices, leading to an FIR for cheating and related offences. The petitioner sought to quash this FIR, arguing the issue was already sub judice before the Supreme Court in the NGT appeals and that the High Court should have quashed it.
Decision Breakdown
The Supreme Court held that the NGT proceedings concerned broad environmental harm to the public at large, while the individual buyer's police complaint concerned a personal claim of being deceived into a specific purchase: these were legally distinct matters, so the pending NGT appeals did not bar a police investigation into the individual's complaint. The Court also rejected the argument that delay in filing the complaint or a discrepancy in the number of vehicles purchased (as per government records) justified quashing the FIR at this preliminary stage, since such factual disputes must be resolved through investigation and trial, not pre-empted by the courts. The Special Leave Petition was accordingly dismissed, leaving the police free to continue investigating.
Lesson Learnt
A company facing a public-interest regulatory case (such as before the NGT) over the same underlying conduct cannot use that pending case as a shield to block a separate criminal complaint from an individual who claims personal loss from the same conduct: courts will generally let police investigations proceed rather than cutting them off early on disputed facts.