Supreme Court Quashes Criminal Case Against Mining Entrepreneurs in Uttar Pradesh

The Supreme Court of India recently delivered a significant judgment in Mahmood Ali & Ors. vs. State of Uttar Pradesh & Ors., quashing a criminal case filed against the appellants in a long-standing dispute over alleged fraud and coercion in the mining sector. The judgment, delivered by B.R. Gavai and J.B. Pardiwala, emphasized the importance of preventing misuse of criminal law to settle personal scores.

This ruling reaffirms the principle that criminal proceedings should not be used as an instrument of harassment. The Court ruled that the case, which was registered 14 years after the alleged incidents, lacked substance and was primarily aimed at targeting the appellants.

Background of the Case

The case revolved around a First Information Report (FIR) No. 127 of 2022, lodged at Mirzapur Police Station, Saharanpur, Uttar Pradesh. The complainant, Ravinder Kumar, claimed that the accused had coerced him into signing papers, misused his name in corporate frauds, and threatened him with false cases.

Chronology of Events

August 1, 2008: The complainant alleged that he was forced to sign blank cheques and other documents.
March 22, 2017: He claimed to have resigned from a company in which he was fraudulently appointed as a director.
June 4, 2022: FIR was filed after a delay of 14 years.
July 8, 2022: The Allahabad High Court refused to quash the FIR.
August 8, 2023: The Supreme Court quashed the FIR.

Petitioner’s Arguments

The appellants, represented by Senior Counsel Siddhartha Dave, contended:

The FIR was filed after an inordinate delay of 14 years.
The allegations were vague, contradictory, and politically motivated.
The complainant never lodged any complaint when he allegedly realized the fraud in 2017.
The petitioners were being targeted due to political and business rivalries.
Multiple FIRs were lodged against the accused, showing a pattern of misuse of criminal law.

Respondent’s Arguments

The State of Uttar Pradesh, represented by Additional Advocate General Garima Prasad, countered:

The accused were involved in organized criminal activities in the mining sector.
There was enough evidence to justify a full-fledged investigation.
The complainant was forced into fraudulent directorships and suffered coercion.
The petitioners had a long criminal history, with multiple cases against them.

Supreme Court’s Analysis

The Supreme Court found that the case fell within the parameters for quashing an FIR as established in State of Haryana v. Bhajan Lal (1992).

1. Absurd and Highly Improbable Allegations

The Court ruled that the allegations did not establish any cognizable offense:

“Even if the entire case of the prosecution is believed to be true, none of the ingredients to constitute the alleged offenses are disclosed.”

2. Delay of 14 Years

The Court held that the delay in filing the FIR was unexplained and unjustifiable:

“The alleged incident occurred in 2008, and the FIR was filed in 2022. Such a delay raises serious doubts about the credibility of the allegations.”

3. Pattern of Multiple FIRs Against the Accused

The judgment noted that multiple FIRs were lodged against the accused, suggesting a pattern of harassment:

“A clear trend emerges where the accused are repeatedly targeted through criminal cases, raising concerns of vendetta.”

4. No Prima Facie Case

The Court ruled that the FIR was a misuse of criminal law:

“The case appears to be manifestly frivolous and vexatious, filed with the ulterior motive of settling personal scores.”

Final Verdict

The Supreme Court ruled:

The FIR No. 127 of 2022 was quashed, and all criminal proceedings were set aside.
The High Court’s refusal to quash the FIR was overturned.
The ruling reaffirmed the need to protect individuals from politically motivated litigation.

This judgment underscores the Supreme Court’s commitment to preventing the misuse of criminal law in business and political disputes. It sets a strong precedent for ensuring that criminal cases are not used as tools of harassment.

Petitioner Name: Mahmood Ali & Ors..
Respondent Name: State of Uttar Pradesh & Ors..
Judgment By: Justice B.R. Gavai, Justice J.B. Pardiwala.
Place Of Incident: Mirzapur, Saharanpur, Uttar Pradesh.
Judgment Date: 08-08-2023.

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