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Suresh Kumar Agrawal v. M/S. Haldia Steels Limited

Criminal Appeal · 2025 INSC 636Decided 15 Apr 2025
Crl.A. No.-001952-001952 - 2025
Justice Vikram Nath · Justice Sandeep Mehta

Background

Haldia Steels Limited entered into an MOU with Suresh Kumar Agrawal for transfer of a manganese mining lease and conversion of his proprietary business into a private company whose shares would go to the company. After paying an advance of Rs. 50 lakhs (against a total of Rs. 3.2 crore due), the company alleged Agrawal never supplied manganese ore and filed a criminal complaint in 2014, six years after the alleged events of 2007-08, accusing him of cheating and criminal breach of trust. Police investigation led to a closure report finding the dispute purely civil, which the trial court accepted, but the Calcutta High Court later directed further investigation.

Decision Breakdown

The Supreme Court held that the complaint was grossly delayed by six years with no explanation, and that the company itself had failed to pay the outstanding Rs. 2.7 crore under the MOU, while Agrawal had already transferred 28% of the incorporated company's shares as promised. The Court found the company had twisted facts, falsely claiming the advance was for manganese-ore supply when the written MOU showed otherwise, and that no evidence supported new allegations of forgery raised only after the closure report. The High Court's order directing further investigation was quashed and set aside as an unjustified exercise of revisional jurisdiction, and the magistrate's order accepting the closure report was restored.

Lesson Learnt

A business dispute arising from breach of a contract or MOU cannot be dressed up as a criminal complaint, especially when filed after years of unexplained delay. Courts will quash such proceedings as an abuse of the legal process.

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

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