The Supreme Court of India delivered a significant ruling in the realm of criminal jurisprudence, reaffirming that in the absence of any criminal intent, criminal proceedings arising out of a civil dispute cannot be allowed to proceed. The reason for this inquiry is to prevent people from misusing criminal law to unnecessarily complicate civil matters.
This was a civil case related to a dispute over property dealings.When a problem arose in the transaction of the property deal, the party filed a civil suit against the respondent and, along with this, also lodged a complaint under Section 406 of the IPC, dealing with criminal breach of trust, and Section 420, dealing with cheating.The complainant alleged that the property owner had deceived him in the property transactions. The Karnataka High Court refused to quash the FIR, and dissatisfied with this decision, the complainant filed an appeal in the Supreme Court.
In this matter the question arise before the court that:
- Whether a criminal proceeding be conducted alongside a civil case? whereas the case is of a civil nature.
- Whether the sections 420 or 402 mentioned in the FIR can make the case prima facie, and whether criminal procedure can be applied in a case of civil nature.
- Whether using criminal proceedings without criminal intent amounts to abusing criminal law.
- Whether the application of criminal procedure in a civil case is against the respondent.
The judgment has been delivered following the principle that a civil case must be adjudicated using civil remedies, and in civil cases, parties cannot use the criminal procedure to exert pressure on other party.
The court's stance is that this matter pertains to a property dispute and there has been no intentional cheating or breach of trust on the part of the respondent.This, the Court held, was crucial for sustaining any prosecution under Sections 406 or 420 IPC.
The court observed that the complaint was filed when the property's market value had significantly increased. After being informed by the court, the complainant admitted that his intention was to file a case against the property to lower its market value so that he could take advantage of it.
This principle formed the foundation of the Court’s reasoning in the present case, The complainant had first filed a civil suit and then intentionally turned this case into a criminal case for his own advantage.
After this case, the court has stated that in this case both civil and criminal laws have been misused and it is an insult to the court. Such matters increase judicial pendency and overburden the court. This case unnecessarily mentally and financially harasses the respondent.
The court says that in such cases, the court should use its inherent powers under Section 482, the Criminal Procedure Code, and Article 132 of the Constitution.
This court order will reduce the court's pendency, which has been caused by unnecessary cases from this side. This ruling of the court will ensure justice for the appellant and compensate for their loss.