Supreme Court Quashes FIR in Dr. Sonia Verma v. State of Haryana Criminal Appeal No. 1433 of 2024

Case: Dr. Sonia Verma v. State of Haryana; Court: Supreme Court of India; Judge: Justices Vikram Nath and Satish Chandra Sharma, JJ.; Case No.: Criminal Appeal No. 1433 of 2024; Decision Date: 07‑03‑2024; Parties: Dr. Sonia Verma & Anr. vs State of Haryana & Anr.

The central controversy presented before this Court concerns the propriety of employing the inherent powers under Section 482 of the Criminal Procedure Code to extinguish criminal proceedings that arise essentially from a dispute of title and possession, matters traditionally adjudicated in civil courts; the appellants contend that the existence of a pending civil suit, coupled with their successful procurement of anticipatory bail, demonstrates that the appropriate forum for resolution is civil, thereby rendering the criminal complaint an abuse of process; consequently, the petition before this Court seeks a declaration that the High Court erred in refusing to quash FIR No. 375/2022, and that the entirety of the criminal proceedings should be set aside.

Facts

The appellants, Dr. Sonia Verma and another, operate Surendra Maternity and Trauma Hospital situated in the village of Suthani, Tehsil Bawal, Rewari, Haryana, and until August 2022 paid a monthly rent of Rs 25,000 to the son of Respondent No. 2; claiming ownership, they assert having purchased the land on 23‑08‑2022 from Sher Singh for Rs 43,00,000, as evidenced by registered sale deed No. 1485, thereby terminating the rental arrangement; pursuing a civil remedy, they instituted Civil Suit No. 294/2022 on 27‑09‑2022 seeking a permanent injunction against Respondent No. 2, her husband, and Babu Lal, an interim injunction being granted on 18‑11‑2022 based on a chain of title comprising four registered deeds; subsequently, Respondent No. 2 lodged FIR No. 375/2022 alleging forgery of the sale deed and unlawful possession, invoking alleged ownership via a transfer deed dated 22‑08‑2017 relating to Killa No. 8; the investigating agency issued a charge‑sheet on 17‑03‑2023, while the appellants obtained anticipatory bail from the Punjab & Haryana High Court and thereafter moved the High Court under Section 482 CrPC for quashing the FIR; the High Court, on 19‑07‑2023, refused the petition, reasoning that the FIR pertained to the disputed Killa No. 8, which the appellants had never claimed to purchase.

Issue

The pivotal question is whether the High Court was justified in declining to invoke the inherent powers under Section 482 CrPC to quash FIR No. 375/2022; the secondary issue concerns whether the existence of a pending civil suit, which directly addresses the title and possession dispute, precludes the initiation of criminal proceedings and mandates the use of the civil forum.

Rule

Section 482 of the Criminal Procedure Code empowers a High Court to exercise inherent powers to prevent abuse of process when criminal proceedings are manifestly oppressive, vexatious, or collateral to a civil remedy; the Supreme Court, citing Paramjeet Batra v. State of Uttarakhand, has held that where a competent civil remedy is available and adopted, the High Court may quash the criminal complaint to avoid duplicative litigation.

Analysis

The Court first examined the factual chronology, noting that the civil suit to determine title was instituted on 27‑09‑2022, preceding the lodging of FIR No. 375/2022 by Respondent No. 2; the petitioners further highlighted that they had already filed FIR No. 372/2022 against Kaptan Singh and co‑accused for fraudulent rent collection, thereby demonstrating a proactive approach to criminal redress where appropriate; the existence of this earlier FIR, coupled with the anticipatory bail order, underscored that the petitioners had not sought to evade criminal liability but to contest the legitimacy of the subsequent complaint; in contrast, Respondent No. 2's FIR targeted only the appellants and Sher Singh, omitting other parties named in the chain of title, an omission that suggested selective prosecution; the Court observed that the substantive allegation—whether the registered sale deed dated 23‑08‑2022 was forged—directly pertains to the validity of title, a question squarely within civil jurisdiction; having recognized the civil nature of the dispute, the Court evaluated the applicability of Section 482, noting that the provision is intended to curb harassment and duplicative litigation, not to supplant a competent civil forum; citing Paramjeet Batra, the Court reiterated that where a civil remedy is both available and actively pursued, the High Court should not hesitate to quash the criminal complaint to prevent abuse of process; the Court further noted that the High Court's reliance on the claim of ownership of Killa No. 8 was misplaced, as the appellants had never asserted title over that parcel, thereby rendering the FIR intrinsically unrelated to the parties' pleadings; consequently, the Court concluded that the criminal proceedings were instituted not on a solid evidentiary foundation but as a stratagem to pressure the appellants in the parallel civil suit; in light of these findings, the Court held that the High Court erred in refusing to exercise its inherent powers, thereby necessitating the setting aside of the FIR and all attendant criminal processes; the order also affirmed that the pending civil suit shall continue unaffected, ensuring that the parties may obtain a definitive determination of title through the appropriate civil mechanism; finally, the Court directed that any applications pending in the criminal matter be disposed of as moot, thereby restoring the appellants' right to proceed unencumbered in the civil forum.

Conclusion

The Supreme Court, by setting aside the High Court's refusal, quashes FIR No. 375/2022, dismisses all criminal proceedings arising therefrom, and affirms the jurisdiction of the pending civil suit to resolve the title dispute.

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