Summary
The Court quashed an electricity-theft FIR lodged after a Lok Adalat award had settled the same demand in full and final satisfaction. The consumer paid the awarded amount, which the electricity supplier accepted without protest. The award reserved no right to initiate criminal proceedings. On these facts, the later FIR contradicted the settlement and lacked a surviving basis.
Issues
- Whether the electricity supplier could lodge an FIR concerning the same demand after a fully satisfied Lok Adalat settlement containing no reservation of that right.
Held
- The award settled the entire dispute over the demand, leaving only recovery of the agreed sum. Payment and acceptance without protest fully satisfied the award. (¶¶ 14, 16–17)
- An aggrieved party’s remedy was to challenge the award in the appropriate forum; no such challenge had been made. (¶ 15)
- The award contained no condition preserving a right to lodge an FIR despite settlement. If the supplier intended to pursue that course, it should have refrained from settling or expressly reserved that right in the award. (¶ 18–19)
- In these circumstances, filing the FIR after the award was unjust, contrary to its terms and unsupported by a subsisting cause arising from the demand. The High Court should have quashed it. (¶ 20–21)
Result
Appeal allowed; High Court order set aside, section 482 petition allowed and FIR No. 548/2015 registered at Malviya Nagar police station quashed.