Criminal law cannot be misused to settle civil disputes: SC

The Supreme Court of India has quashed a criminal case filed against an individual Anukul Singh in Moradabad, Uttar Pradesh, calling it malicious and a clear abuse of the legal process. A bench of Justices BV Nagarathna and R Mahadevan heard the case stemming from a property dispute.The ruling sends a strong message that civil disputes cannot be converted into criminal cases, just to harass someone.

The dispute began in 2000 when Singh’s father purchased over eight hectares of land in Village Sherpur Mafi, Tehsil Bilari, District Moradabad, Uttar Pradesh. The land was traditionally used for Qurbani (religious sacrifice), and local religious authorities, including the Shaher Imam of Bilari, objected to the transfer, claiming the land was needed for religious purposes. Singh and his family resisted these demands, asserting their legal ownership. This resistance triggered tensions with the Shaher Imam and local officials, who allegedly pressured the local police to act against Singh. The court clarified this stance while pronouncing its judgment in the case Singh v. Shaher Imam & Others (Moradabad District Court, 2025), stating that the Singh family’s ownership was legally valid and that religious authorities could not claim the land without proper legal title.

Within a short span, eight FIRs were filed against Singh, including accusations of cheating, forgery, and dishonoured cheques. The Supreme Court noted that these criminal complaints were filed in quick succession as a retaliatory measure, aimed at punishing Singh for opposing the demands and asserting his rights over the land.

The main case, FIR No. 47 of 2003, claimed that Singh had provided a loan of Rs. 1.4 lakh instead of Rs. 2 lakh and coerced the complainant into signing certain documents. Even if all allegations were assumed to be true, the Court observed, “they unmistakably arise out of a commercial / contractual transaction relating to loan and repayment, which has been given a criminal colour….the machinery of criminal law cannot be permitted to be misused for settling civil disputes or to wreak vengeance.” Singh had already filed complaints under the Negotiable Instruments Act, and the complainant was later convicted for dishonoured cheques, strengthening the Court’s conclusion that the FIR was malicious and retaliatory.

While the High Court had earlier refused to quash the case, the Supreme Court clarified that criminal proceedings cannot be used to settle civil disputes or exact revenge. Accordingly, the FIR and the resulting charge sheet were quashed, but the parties remain free to pursue civil remedies.

Key takeaways:

• Criminal law cannot be misused to settle civil or financial disputes.

• Courts can intervene when cases are filed maliciously to harass someone.