VidhiSangh

Supreme Court of India · 02/03/2020

SAMTA NAIDU & ANR. versus STATE OF MADHYA PRADESH & ANR.

[2020] 2 S.C.R. 1127 · 2020 INSC 248

AI-generated headnote. Verify against the judgment before relying on it. Paragraph numbers refer to the judgment.

Summary

The Supreme Court dismissed a second criminal complaint concerning an allegedly forged vehicle sale as not maintainable. The earlier complaint had been considered on its merits and dismissed under Section 203 CrPC. The later credit note and registration documents merely supported the same core allegations, with no explanation why reasonable diligence could not have secured them earlier. The appellants’ deposit was ordered returned with accrued interest.

Issues

  1. When a second complaint on the same allegations can follow dismissal of an earlier complaint.
  2. Whether the additional documents established an exceptional basis for the second complaint here.

Held

Result

Appeals allowed; High Court decision set aside and Complaint Case 9226/2014 dismissed as not maintainable. Appellants’ deposited amount directed to be returned with accrued interest.

Judgment PDF: Supreme Court of India, [2020] 2 S.C.R. 1127.