VidhiSangh

Supreme Court of India · 07/03/2024

DR SONIA VERMA & ANR. versus THE STATE OF HARYANA & ANR.

[2024] 3 S.C.R. 673 · 2024 INSC 227

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Summary

On the particular property and litigation record, the criminal complaint was an attempt to give a civil title and possession dispute a criminal character. The purchasers relied on a chain of registered deeds and had already sought civil protection; the counter-FIR followed that suit and their own complaint. Selective accusations and other circumstances reinforced the conclusion of abuse. The Court quashed all proceedings arising from the impugned FIR while leaving the pending civil suit and deed-validity questions entirely unaffected.

Issues

  1. Whether the challenged FIR disclosed an independent criminal basis or merely recast the title dispute.
  2. What significance the deed chain and litigation sequence had.
  3. What effect quashing should have on the civil proceedings.

Provisions considered

Held

Result

Appeal allowed; High Court order set aside and all criminal proceedings arising from FIR 375/2022 quashed. Pending civil suit and its title and deed-validity issues expressly left unaffected.

Judgment PDF: Supreme Court of India, [2024] 3 S.C.R. 673.