Anukul Singh Vs State of Uttar Pradesh And Anr. (Supreme Court of India)
Summary: The Supreme Court allowed the criminal appeal filed by Anukul Singh against the Allahabad High Court order dated 22.10.2019 refusing to quash proceedings arising from FIR No. 47 of 2003 registered under Sections 420, 467 and 468 of the Indian Penal Code, 1860. The appellant contended that the FIR was a counterblast to earlier proceedings and formed part of multiple criminal cases allegedly initiated against him in connection with a civil dispute concerning land, loan repayment and execution of documents. The Court considered the settled principles governing exercise of inherent jurisdiction under Section 482 Cr.P.C., including the illustrative categories laid down in State of Haryana v. Bhajan Lal. It observed that although the High Court cannot conduct a mini-trial or appreciate disputed evidence, it may intervene where unimpeachable material demonstrates abuse of process. On the facts, the Court held that the dispute concerning repayment of loan money and alleged coercion in execution of documents was purely civil in character, that the essential ingredients of cheating or forgery were not prima facie made out, and that the multiple FIRs reinforced the inference of mala fides. The impugned High Court judgment was therefore set aside and FIR No. 47 of 2003 and consequential charge sheet dated 16.04.2003 were quashed, while leaving the parties free to pursue civil remedies available in law.
