Criminal Law Cannot Be Used to Further the Cause In A Purely Civil Dispute: SC

The Supreme Court has reiterated that criminal proceedings cannot be weaponized to resolve disputes of a purely civil nature, especially when civil litigation is already pending between the parties.

A division bench comprising Justice Sanjay Kumar and Justice K. Vinod Chandran set aside the criminal proceedings against an appellant, noting that the allegations regarding the execution of allegedly 'fake' General Power of Attorneys (GPAs) lacked criminal elements and primarily involved land title disputes.

No Criminal Liability for Conveying Property Beyond Title

The Court examined the nature of the allegations where the appellant and her mother were accused of executing GPAs for land, a portion of which had been transferred to the State of Uttar Pradesh. The bench noted that even if a vendor conveys more property than they have title over, it does not inherently attract criminal liability.

The Court, in its reasoning, observed: "Further the jamabandi having been noticed in the sale deed or the vendors having conveyed more property than they had title over cannot lead to any criminal liability as such; which if at all alleged, should be by the purchasers. Here, a person alleged to be in occupation of a land has filed the complaint and we are unable to find any reason on facts as disclosed from the FIR to even allege any criminality on the appellant herein. Admittedly, there is a civil suit pending as initiated by the de-facto complainant. Criminal law cannot be used to further the cause in a purely civil dispute."

Supplementary FIR Without New Evidence Frowned Upon

During the proceedings, the appellant's counsel highlighted that while the appellant's name was mentioned in the first FIR, she was not arrayed as an accused. She was only included through a supplementary FIR despite no new material being unearthed. The counsel relied on Mariam Fasihuddin & Anr. v. State by Adugodi Police Station & Anr. ( "(2024) 11 SCC 733": 2024 CaseBase(SC) 409), where the Court had previously discouraged the submission of supplementary reports in the absence of fresh evidence.

The Court has the following directions:

"We, hence, quash FIR No.588 dated 02.06.2018, Annexure P10, registered at Faridabad Central Police Station and all consequential proceedings insofar, the appellant herein is concerned."

Background:

The dispute arose from an FIR registered at Faridabad Central Police Station involving allegations of forged GPAs and land transfers. The appellant, the daughter of the title holders, was accused along with her mother of executing documents for land they no longer fully owned. The High Court had declined to quash the FIR, holding that the 'criminal elements' involving the alleged forgery could not be ignored despite the civil nature of the land dispute.

However, the Supreme Court found that the de-facto complainant was merely an occupier and not the purchaser who might have been allegedly defrauded. Finding no prima facie criminality, the Apex Court allowed the appeal and quashed the proceedings against the appellant.

Case Details:
Case No.: CRIMINAL APPEAL NO.2457 OF 2026
NeutralCitation: 2026 INSC 530
Case Title: Sunisha Anand v. State of Haryana & Anr.
Appearances:
For the Petitioner(s): Sri Siddharth Luthra, Senior Counsel
For the Respondent(s): Sri Abhinav Bajaj, Additional Attorney General

Source: 2026 CaseBase(SC) 586