As per case facts, petitioners Sakinder Singh and Darshan Singh sought to quash an FIR registered for cheating and criminal conspiracy related to a land sale. They, along with a ...
CRM-M-21633-2018 (O&M)
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IN THE HIGH COURT OF PUNJAB & HARYANA
AT CHANDIGARH
1. CRM-M-21633-2018 (O&M)
Sakinder Singh ...Petitioner
Versus
State of Punjab and others ...Respondent s
2. CRM-M-23345-2018 (O&M)
Darshan Singh ...Petitioner
Versus
State of Punjab and others ...Respondents
Sr. No.
Particulars Details
1 The date when the judgment is reserved 08.05.2026
2 The date when the judgment is pronounced 12.05.20 26
3 The date when the judgment is uploaded on the website 12.05.2026
4
Whether only operative part of the judgment is pronounced or full
judgment is pronounced
Full
5
The delay, if any, of the pronouncement of full judgment, and
reasons thereof
Not
applicable
CORAM: HON'BLE MRS. JUSTICE MANISHA BATRA
Present: Mr. P.S. Paul, Advocate for the petitioners.
(in both cases)
Ms. Ruchika Sabherwal, Sr. DAG, Punjab.
Mr. Jagjit Singh, Advocate for respondents No.2 and 3.
***
MANISHA BATRA, J.
1. This order shall dispose of the aforementioned two petitions
which have been filed by the petitioners seeking quashing of a common FIR
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bearing FIR No. 702 dated 30.12.2017, registered under Sections 420 and
120-B of IPC at Police Station Morinda, District Roopnagar along with all the
subsequent proceedings having arisen therefrom.
2. Brief facts relevant for the purpose of disposal of these petitions
are that the aforementioned FIR was registered on the basis of a complaint
jointly submitted by the respondents No. 2 and 3-complainants/Kulwant
Singh and Raj Kumar alleging that the present petitioners and Surinder Kaur,
wife of petitioner-Darshan Singh, had approached them making offer to sell
land owned by Surinder Kaur in village Nathmalpur by representing that the
said land was free from all encumbrances and Surinder Kaur was the absolute
owner of the same. They had also shown the said land to the respondents No.
2 and 3 and had also told them that the victims could get this land leased out
any person till the date of registration of sale deed. On being induced by the
petitioners and co-accused, the victims had entered into an agreement to
purchase this land for a sum of Rs. 29,50,000/- per acre. A written agreement
was executed by Surinder Kaur in favour of the victims and she received a
sum of Rs. 20,00,000/- as earnest money. The sale deed was to be executed
on 30.12.2015. However, thereafter, Surinder Kaur and her husband petitioner
Darshan Singh started avoiding execution of sale deed. They made the victims
enter into another agreement to sell on 31.08.2015 and received another sum
of Rs. 16,00,000/- from them while making promise to execute sale deed by
24.09.2015. At the time when the sale deed was to be executed, the victims,
however, came to know that Surinder Kaur is not the absolute owner of the
land in question and a dispute relating to mutation of the same was pending
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before the Commissioner, Rupnagar and civil litigation between Surinder
Kaur and some other legal heirs of her predecessor, was also pending. By
alleging that while fully knowing about these facts, the petitioners and the co-
accused concealed the same with intent to cheat the victims, thereby causing
wrongful loss of an amount of Rs. 36,00,000/- to them, the victims prayed for
registration of FIR.
3. After registration of FIR, investigation proceedings were
initiated. The petitioners and the accused Surinder Kaur joined investigation
and were arrested. Investigation now stands completed and they are facing
trial for commission of the aforementioned offences. They had moved an
application for discharge which has been dismissed by the learned trial Court
vide order dated 29.07.2025.
4. It is argued by learned counsel for the petitioner-Darshan Singh
that he has been falsely implicated in this case. There is delay of about two
years in lodging of the FIR, which has not been explained. He was neither a
witness to the agreement to sell nor signatory to any document. He is not
beneficiary of the agreement to sell. The dispute between the parties is of civil
nature which has been given a criminal colour. At the time when the
agreement to sell was executed and when the private respondents paid the
earnest money, there was no order of stay passed by any Civil Court and
accused Surinder Kaur was very much competent to execute agreement to sell
qua the land in question which she had inherited from her father on the basis
of a Will. As such, no dishonest intention could be attributed to even accused
Surinder Kaur, what to talk about having any malafide with him. The
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ingredients for commission of offence punishable under Section 420 of IPC
are not at all attracted qua him. The FIR has been lodged to abuse the process
of law. There are no chances of the FIR culminating into conviction of the
petitioner. It is thus argued that the petition deserves to be allowed and the
FIR in question is liable to be quashed.
5. While addressing arguments on behalf of petitioner Sikandar
Singh, learned counsel for the petitioner has argued that there is delay of more
than two years in lodging of the FIR which has not been explained. The
petitioner was only an attesting witness to the agreement to sell which was
executed between the parties on 24.09.2015. He is not at all beneficiary to the
transaction. No money whatsoever has been received by him from the
complainants. There was no inducement by him of any kind to the victims.
The dispute between the parties is of civil nature which has been given a
criminal colour. The proceedings arising out of the FIR have been initiated to
abuse the process of law. It is, therefore, argued that the petition deserves to
be allowed. To fortify his arguments, learned counsel for the petitioners has
relied upon Inder Mohan Goswami & Anr v. State of Uttaranchal & Ors.
2007 (4) RCR (Criminal) 548, Madan Lal & Anr. v. State of Haryana &
Anr. 2012 (3) RCR (Criminal) 643, Sardar Ali Khan v. State of U.P through
Principal Secretary Home Department & Anr, 2020 (1) RCR (Criminal) 823
Surjit Singh v. State of Punjab and another, 2018 (4) RCR (Criminal) 157,
Sanjay Agarwal v. State of Odisha & Anr. Etc, 2024 (184) SCL 538
Law Finder Doc Id # 2594683 A.M. Mohan v. The State Represented By
SHO And Another, 2024 (2) RCR (Criminal) 380.
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6. Per contra, learned State counsel, assisted by learned counsel for
respondents No. 2 and 3, has argued that there are specific allegations against
the petitioners. Challan has been presented. However, due to the stay order
granted by this Court, charges were could not be framed. Thorough inquiry
had been conducted in the matter and the allegations levelled against the
petitioners were prima facie made out. The veracity of the allegations as
levelled against the petitioners can be tested in the trial and no ground for
quashing the FIR has been made out. Therefore, it is urged that the petition is
liable to be dismissed.
7. This Court has heard the rival submissions.
8. At the outset, it will be profitable to look into the scope and ambit
of the Court’s power under Section 482 Cr.P.C. (which is pari materia with
Section 528 of Bharatiya Nagarik Suraksha Sanhita, 2023) as spelt out in
several judicial pronouncements of Hon’ble Supreme Court as well as
different High Courts. The well settled proposition of law is that in exercise
of inherent powers under Section 482 Cr.P.C., the High Court is not expected
to analyze all the facts, which are to be placed before the High Court. The
power conferred under this section is very specific. To secure the ends of
justice, to prevent the abuse of process of Court or to make any such orders as
may be necessary to give effect to any order under the Code, such power can
be exercised to prevent abuse of process of Court. The Hon’ble Supreme
Court has drawn up some guidelines in some categories of cases by way of
illustration to circumscribe the exercise of inherent power under Section 482
of Cr.P.C. to prevent abuse of process of any Court or to securethe ends of the
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justice or to give effect to an order of the Court. A celebrated pronouncement
on this point is the case cited as State of Haryana Vs. Bhajan Lal : 1992
SUPP (1) SCC 335, wherein Hon’ble Supreme Court has discussed different
categories of cases wherein the power under Section 482 Cr.P.C. could be
exercised either to prevent abuse of process of law or otherwise to secure the
ends of justice, while observing that it might not be possible to lay down any
precise, clearly defined, sufficiently channelized, inflexible guidelines or rigid
formulae and to give an exhaustive list or myriad kind of cases where such
powers should be exercised. The following principles have been culled out:-
“102 (1) Where the allegations made in the First Information
Report or the complaint, even if they are taken at their face
value and accepted in their entirety do not prima facie
constitute any offence or make out a case against the accused;
(2) Where the allegations in the First Information Report and
other materials, if any, accompanying the FIR do not disclose
a cognizable offence, justifying an investigation by police
officers under Section 156(1) of the Code except under an
order of a Magistrate within the purview of Section 155(2) of
the Code;
(3) Where the uncontroverted allegations made in the FIR or
complaint and the evidence collected in support of the same
do not disclose the commission of any offence and make out
a case against the accused;
(4) Where the allegations in the FIR do not constitute a
cognizable offence but constitute only a non-cognizable
offence, no investigation is permitted by a police officer
without an order of a Magistrate as contemplated under
Section 155 (2) of the Code;
(5) Where the allegations made in the FIR or complaint are
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so absurd and inherently improbable on the basis of which no
prudent person can ever reach a just conclusion that there is
sufficient ground for proceeding against the accused;
(6) Where there is an express legal bar engrafted in any of the
provisions of the Code or the concerned Act (under which a
criminal proceeding is instituted) to the institution and
continuance of the proceedings and/or where there is a
specific provision in the Code or the concerned Act,
providing efficacious redress for the grievance of the
aggrieved party;
(7) Where a criminal proceeding is manifestly attended with
mala fide and/or where the proceeding is maliciously
instituted with an ulterior motive for wreaking vengeance on
the accused and with a view to spite him due to private and
personal grudge.”
9. The principles of law as laid down by Hon’ble Supreme Court in
Bhajan Lal’s case (supra) have been followed in a catena of judgments. In
Paramjeet Batra vs. State of Uttarakhand, (2013) 11 SCC 673, it was
observed by Hon’ble Supreme Court that although the inherent powers of a
High Court under Section 482 of the Code should be exercised sparingly and
only for the purpose of preventing abuse of process of any Court or otherwise
to secure ends of justice, yet, the High Court must not hesitate in quashing
such criminal proceedings, where essential ingredients of the offence are not
made out. In Mahendra K.C. vs. State of Karnataka, (2022) 2 SCC 129:
(2022) 1 SCC (Cri) 401, Hon’ble Supreme Court observed that the test to be
applied is whether the allegations in the complaint, as they stand, without
adding or detracting from the complaint, prima facie establish the ingredients
of the offence alleged. At this stage, the High Court cannot test the veracity of
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the allegations, nor, for that matter, can it proceed in the manner that a judge
conducting a trial would, based on the evidence collected during the course of
the trial. In Priyanka Jaiswal vs. State of Jharkhand, 2024 SCC Online SC
685, Hon’ble Supreme Court observed that the Court exercising extraordinary
jurisdiction under Section 482 of Cr.P.C. cannot conduct a mini trial or enter
into appreciation of evidence of a particular case. The following observations
were made:
“13. We say so for reasons more than one. This Court in
catena of Judgments has consistently held that at the time
of examining the prayer for quashing of the criminal
proceedings, the court exercising extra-ordinary
jurisdiction can neither undertake to conduct a mini trial
nor enter into appreciation of evidence of a particular case.
The correctness or otherwise of the allegations made in the
complaint cannot be examined on the touchstone of the
probable defence that the accused may raise to stave off
the prosecution and any such misadventure by the Courts
resulting in proceedings being quashed would be set aside.
This Court in the case of Akhil Sharda1 held to the
following effect:
“28. Having gone through the impugned
judgment and order passed by the High Court
by which the High Court has set aside the
criminal proceedings in exercise of powers
under Section 482 Cr.P.C., it appears that the
High Court has virtually conducted a mini
trial, which as such is not permissible at this
stage and while deciding the application
under Section 482 Cr.P.C. As observed and
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held by this Court in a catena of decisions no
mini trial can be conducted by the High Court
in exercise of powers under Section 482
Cr.P.C. jurisdiction and at the stage of
deciding the application under Section 482
Cr.P.C., the High Court cannot get into
appreciation of evidence of the particular case
being considered.”
10. Similar view was taken in Minakshi Yadav vs. State of Uttar
Pradesh, 2024 SCC Online 643, wherein Hon’ble Supreme Court observed
that the Court would not be justified in embarking upon an inquiry as to the
reliability and genuineness or otherwise of the allegations made in the FIR or
the complaint at the stage of quashing of the proceedings under Section 482
of Cr.P.C.
11. Reference can further be made to Gian Singh vs. State of Punjab,
(2012) 10 SCC 303, wherein Hon’ble Supreme Court observed that the power
of the High Court in quashing a criminal complaint or an FIR, in exercise of
its inherent jurisdiction, is distinct and different from the power given to a
criminal court for compounding the offences under
Section 320 of the Code.
Inherent power is of wide plenitude with no statutory limitation but it has to
be exercised in accordance with the guidelines engrafted in such power viz;
(i) to secure the ends of justice or (ii) to prevent abuse of the process of any
Court.
12. In Neeharika Infrastructure vs. State of Maharashtra : 2021
SCC OnLine SC 315, the Apex Court observed that the Courts ought to be
cautious in exercising powers under Section 482 of Cr.P.C. They do have
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power to quash. The test is whether or not the allegations in the FIR disclose
the commission of a cognizable offence? The merits of the allegations are not
to be entered into nor the power of the investigating agency to investigate into
allegations involving the commission of a cognizable offence is to be trenched
upon.
13. Similar position of law was reiterated by Hon’ble Supreme Court
in Ajay Malik vs. State of Uttarakhand, 2025 SCC OnLine SC 185, wherein
it was observed as follows:
“8. It is well established that a High Court, in exercising
its extraordinary powers under Section 482 of the CrPC,
may issue orders to prevent the abuse of court processes or
to secure the ends of justice. These inherent powers are
neither controlled nor limited by any other statutory
provision. However, given the broad and profound nature
of this authority, the High Court must exercise it sparingly.
The conditions for invoking such powers are embedded
within Section 482 of the CrPC itself, allowing the High
Court to act only in cases of clear abuse of process or
where intervention is essential to uphold the ends of justice.
9. It is in this backdrop that this Court, over the course of
several decades, has laid down the principles and
guidelines that High Courts must follow before quashing
criminal proceedings at the threshold, thereby pre-empting
the Prosecution from building its case before the Trial
Court. The grounds for quashing, inter alia, contemplate
the following situations : (i) the criminal complaint has
been filed with mala fides; (ii) the FIR represents an abuse
of the legal process; (iii) no prima facie offence is made
out; (iv) the dispute is civil in nature; (v.) the complaint
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contains vague and omnibus allegations; and (vi) the
parties are willing to settle and compound the dispute
amicably (State of Haryana v. Bhajan Lal, 1992 Supp (1)
SCC 335).”
14. Now coming to the present case. The petitioners have been
booked for commission of offences punishable under Section 420 read with
Section 120-B of IPC on the allegations that they, in connivance with co-
accused Surinder Kaur, had cheated complainants of huge amount of money
on the pretext of selling them some land. The offence of cheating is defined
under Section 415 of IPC and cheating a person, thereby dishonestly inducing
him to deliver any property falls within the ambit of Section 420 of IPC. The
ingredients required to constitute Offence of cheating under Section 415 of
IPC are as follows:
(i) There should be fraudulent or dishonest inducement
of a person by deceiving him;
(ii) (a) The person so deceived should be induced to
deliver any property to any person, or to consent that
any person shall retain any property; or
(b) The persons so deceived should be intentionally
induced to do or omit to do anything which he would
not do or omit if he were not so deceived; and
(iii) In cases covered by (ii)(b) the act or omission
should be one which causes or is likely to cause damage
or harm to the person induced in body, mind,
reputation or property.
15. Further, the ingredients for commission of offence punishable
under Section 420 of IPC are as follows:
(i) Cheating;
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(ii) Dishonest inducement to deliver property or to
make, alter or destroy any valuable security or
anything which is sealed or signed or is capable of
being converted into valuable security, and
(iii) Mens rea of the accused at the time of making the
inducement.
16. It is clear from the above that to constitute the offence of cheating,
there must be fraudulent or dishonest inducement of a person with intention
to deceive him and such person must have been deceived to deliver any
property or to give consent to retain such property or to omit to do anything
or to make alter or destroy the whole or any part of valuable security.
Simultaneously, mens rea of the accused at the time of making such
inducement must also to be established.
17. On applying the ratio of law laid down in the afore-discussed
authorities, this Court finds that specific allegations have been levelled in the
FIR that the petitioners along with co-accused Surinder Kaur had approached
the complainants and induced them to enter into the agreement to purchase
the land in question by representing that the same was free from all
encumbrances and that Surinder Kaur was absolute owner thereof. It has
further come on record that despite pendency of dispute regarding mutation
and civil litigation qua the property, the complainants were allegedly kept in
dark and substantial amount of Rs.36,00,000/- was obtained from them. The
allegations contained in the FIR, if taken at their face value, prima facie
disclose the ingredients of offences punishable under Sections 420 and 120-B
IPC. At this stage, this Court cannot embark upon appreciation of evidence or
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adjudicate upon the defence sought to be raised by the petitioners that Surinder
Kaur had valid title on the basis of a Will or that there was no dishonest
intention on their part. Such disputed questions are matters of trial and cannot
be examined in proceedings under Section 482 Cr.P.C./Section 528 BNSS.
The contention regarding delay in lodging of the FIR or the plea that the
dispute is purely civil in nature are also matters which would require
appreciation of evidence and cannot by themselves be made basis for quashing
where the allegations prima facie disclose commission of cognizable offences
involving deception and dishonest inducement.
18. So far as petitioner-Darshan Singh is concerned, though it has
been argued that he was neither signatory nor beneficiary to the agreement to
sell, yet the FIR specifically attributes active role to him in approaching the
complainants along with co-accused Surinder Kaur, inducing them to enter
into the transaction and subsequently avoiding execution of the sale deed. The
allegations further indicate that he was aware about the pending dispute
relating to the property and yet allegedly concealed the same from the
complainants. Whether he had actually participated in the conspiracy or
possessed the requisite mens rea are questions which can only be determined
after evidence is led before the trial Court. At this stage, the material collected
during investigation cannot be discarded by conducting a mini trial while
exercising inherent jurisdiction.
19. As regards petitioner-Sikandar Singh, the contention raised is
that he was merely an attesting witness to the agreement to sell and had not
received any amount from the complainants. However, merely because a
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person is described as an attesting witness would not ipso facto absolve him
from criminal liability where there are specific allegations of dishonest
intention on his part since the very inception. A perusal of the contents of the
FIR would show that it was petitioner Sakinder Singh, who along with
petitioner Darshan Singh had approached the victims and had represented that
wife of Darshan Singh was the absolute owner of the land in dispute and she
wanted to sell the same. There is specific allegations that all the three accused
kept the victims under an impression that the land in dispute was free from all
encumbrances. Hence, it cannot be said that petitioner Sakinder Singh was
simpliciter an attesting witness to the aforementioned agreement to sell.
Reference in this regard can be made to the authority cited as Mohammad
Sadeek @ Sadiq Khan v. State of Punjab, CRR-389-2022, decided on
09.03.2022, wherein it has been held by this Court that in a case involving
agreement to sell and subsequent fraudulent sale deed execution, dishonest
intention from the inception and active participation by an accused as attesting
witness are sufficient to establish culpability for cheating. The role attributed
to petitioner Sakinder Singh and the extent of his involvement are matters to
be tested during trial. In the present case, the allegations are not confined
merely to execution of documents but extend to active inducement and
concealment of material facts relating to title of the property. Therefore, at this
stage, this Court is unable to conclude that no prima facie case is made out
against petitioner-Sikandar Singh.
20. The judgments relied upon by learned counsel for the petitioners
are distinguishable on facts and do not advance the case of the petitioners in
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view of the specific allegations levelled in the FIR and the material collected
during investigation. It is settled proposition of law that where the allegations
prima facie disclose commission of cognizable offences, the proceedings
ought not to be scuttled at the threshold by exercising inherent jurisdiction.
Consequently, this Court does not find the present case to be falling within
any of the parameters laid down in Bhajan Lal’s case (supra) warranting
interference under Section 482 Cr.P.C./Section 528 BNSS. Both the petitions
being devoid of merit are accordingly dismissed. Any observation made
hereinabove shall not be construed as expression on merits of the case and
shall have no bearing upon the trial proceedings.
21. Let a photocopy of this order be placed on the file of the
connected case.
(MANISHA BATRA)
JUDGE
12.05.2026
Waseem R. AnsariWaseem R. AnsariWaseem R. AnsariWaseem R. Ansari
Whether speaking/ reasoned : Yes / No
Whether reportable : Yes / No
This landmark decision from the High Court of Punjab & Haryana addresses critical legal questions surrounding Quashing FIR and the nuanced application of Cheating IPC 420 offences. The case, involving petitions by Sakinder Singh and Darshan Singh, highlights the judiciary's approach to allegations of fraud in property transactions, with its full details and implications now accessible on CaseOn for comprehensive legal review.
The central question before the High Court was whether the FIR (No. 702 dated 30.12.2017), registered against the petitioners under Sections 420 (Cheating) and 120-B (Criminal Conspiracy) of the Indian Penal Code (IPC), along with all subsequent legal proceedings, should be dismissed. The petitioners argued that the accusations did not amount to a recognizable crime, that the dispute was civil, and that they had been wrongly implicated.
The Court relied on established legal principles governing the power to dismiss an FIR, primarily Section 482 of the Criminal Procedure Code (Cr.P.C.), which is equivalent to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023. Key judicial pronouncements guiding this power include:
For legal professionals seeking swift insights into such complex rulings, CaseOn.in offers 2-minute audio briefs that efficiently distill the essence of these judgments, aiding in quick analysis and application of specific legal precedents like those cited in this case.
The FIR claimed that petitioners Sakinder Singh and Darshan Singh, along with Darshan Singh's wife Surinder Kaur, convinced the complainants (Kulwant Singh and Raj Kumar) to enter into a land purchase agreement. They falsely stated that Surinder Kaur was the undisputed owner and that the land was free from any debts or claims. The complainants paid Rs. 36,00,000/- (Rs. 20 lakhs initially, then Rs. 16 lakhs) as advance payment. Later, the complainants discovered ongoing disputes regarding property transfer and civil lawsuits, which showed that Surinder Kaur was not the sole owner. The petitioners allegedly hid these critical facts with the intention of defrauding them.
Darshan Singh argued that he was not a signer, beneficiary, or witness, asserting that the dispute was civil and Surinder Kaur had valid ownership through a Will. However, the Court observed that the FIR specifically assigned an “active role” to him in approaching, misleading, and later avoiding the sale deed, and that he was aware of the ongoing disputes. The Court clarified that whether he had a criminal intent (mens rea) or was part of a conspiracy could only be determined during a trial, not at the stage of quashing the FIR. His defense required evaluating evidence, which is not allowed under Section 482 Cr.P.C.
Sakinder Singh claimed he was merely an attesting witness and received no money. However, the Court noted that the FIR alleged he also approached the victims and made false claims about the land’s ownership and clear title. This indicated active encouragement and dishonest intent from the beginning, not just a passive role as a witness. The Court referenced Mohammad Sadeek @ Sadiq Khan v. State of Punjab (2022), which held that an attesting witness with dishonest intent and active involvement can be guilty of cheating. The extent of his involvement was deemed a matter for trial.
The Court concluded that the allegations, taken at face value, clearly showed the commission of serious offenses under Sections 420 and 120-B IPC. Arguments about the delay in filing the FIR, the civil nature of the dispute, or the petitioners’ specific roles and intentions were considered matters requiring the assessment of evidence, which falls outside the scope of Section 482 Cr.P.C. The Court stressed that it could not conduct a “mini-trial” to verify the allegations at this early stage.
The High Court dismissed both petitions (CRM-M-21633-2018 and CRM-M-23345-2018), determining that the case did not meet the criteria outlined in Bhajan Lal’s case for intervention under Section 482 Cr.P.C. or Section 528 BNSS. The Court reiterated that since the FIR prima facie indicated serious offenses, the proceedings should not be stopped prematurely. Any comments made in this order were explicitly stated not to reflect on the merits of the case and would not affect the trial proceedings.
This judgment serves as a critical reminder for lawyers and law students about the strict boundaries of inherent powers under Section 482 Cr.P.C. (or Section 528 BNSS) for Quashing FIR. It reinforces the principle that courts will not conduct a “mini-trial” or evaluate evidence at the initial stage of legal proceedings. The case clearly shows how allegations of fraud, misrepresentation, and criminal conspiracy, even if they appear to be civil in nature, can lead to criminal liability if dishonest intent (mens rea) from the beginning can be initially established. Furthermore, it highlights that even an “attesting witness” can be implicated if active inducement and concealment of important facts are alleged, moving beyond a passive role. Understanding this distinction is essential for planning defense strategies in similar cases and for advising clients on the potential criminal consequences of property disputes involving deception.
All information provided in this analysis is for general informational purposes only and does not constitute legal advice. It is recommended to consult with a qualified legal professional for advice on specific legal issues.
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