State Of Madhya Pradesh vs Shilpa Jain 2024 INSC 278 :: [2024] 4 S.C.R. 372 – Revenue Records – S 482 CrPC

Revenue Records – Revenue records are not documents of title; and nor would any findings pursuant to revenue proceedings under the Code confer any rights, title or interest – Questions of title can only be determined by a civil court of competent jurisdiction.

Code Of Criminal Procedure, 1973; Section 482 – Principles governing the exercise of jurisdiction of the High Court under Section 482 of the CrPC vis-à-vis the quashing of an FIR – Referred to State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335 – Interplay between civil disputes and criminal proceedings – Referred to Mohd. Ibrahim v. State of Bihar, (2009) 8 SCC 751 – Neither does the present case satisfy any of the parameters laid down by this Court in Bhajan Lal (Supra) warranting the exercise of jurisdiction under Section 482 of the CrPC vis-à-vis the quashing of an FIR; and nor can the allegation(s) levelled against the accused person(s) be classified as ‘purely civil in nature’ or merely ‘cloaked as a criminal offence’. Undoubtedly, the genesis of the present dispute emanates from civil proceedings qua the possession of the Suit Property, however, the dispute in its current avatar i.e. as is discernible from the allegation levelled against the Respondents in the FIR, has certainly undergone a metamorphosis into a criminal dispute which ought not to have been scuttled at the threshold, and in fact ought to have been considered on its own merits, in accordance with law. (Para 7)

Leave a Comment

Your email address will not be published. Required fields are marked *