Supreme Court Quashes Criminal Proceedings in Haryana Property Dispute

The Supreme Court of India has quashed a criminal complaint arising from a land dispute in Haryana, ruling that the allegations were primarily civil in nature and did not warrant criminal prosecution. The case, Dr. Sonia Verma & Anr. vs. The State of Haryana & Anr., involved a dispute over the ownership of land on which a hospital was built. The complainant alleged forgery and criminal conspiracy, while the appellants argued that the issue was a civil matter and should not be pursued as a criminal offense.

The Supreme Court set aside the Punjab and Haryana High Court’s refusal to quash the FIR, emphasizing that criminal proceedings cannot be used as a means to settle civil disputes.

Background of the Case

The dispute arose over the ownership of land in village Suthani, Tehsil Bawal, Rewari, Haryana, where the appellants, Dr. Sonia Verma & Dr. Rakesh Verma, operated Surendra Maternity and Trauma Hospital. The hospital was initially on rented premises, and the appellants were paying ₹25,000 per month as rent to the son of the complainant (Respondent No. 2).

1. Sale of Land and Civil Suit

On August 23, 2022, the appellants purchased the land via a registered sale deed from one Sher Singh for ₹43,00,000.
After purchasing the property, the appellants stopped paying rent to the complainant’s son, claiming ownership of the land.
Fearing dispossession, they filed a civil suit (No. 294/2022) on September 27, 2022, seeking a permanent injunction against the complainant and her family.
The Civil Court granted ad-interim relief on November 18, 2022, finding a prima facie case in favor of the appellants.

2. Criminal Proceedings Initiated by the Complainant

On October 31, 2022, the complainant filed an FIR (No. 375/2022) against the appellants and Sher Singh under Sections 506, 420, 34, 120-B, and 467 IPC, alleging forgery and conspiracy.
She claimed ownership of the land under a Transfer Deed dated August 22, 2017, and accused the appellants of illegally acquiring her property.
The police filed a charge sheet on March 17, 2023, and the appellants obtained anticipatory bail.

Arguments Before the Supreme Court

1. Appellants’ Arguments

The appellants contended that the FIR was an attempt to harass them and that the dispute was purely civil.
They pointed out that they had filed a civil suit before the FIR was lodged.
The validity of the sale deed was already under scrutiny in the civil court.

2. Respondent’s Arguments

The State of Haryana argued that sufficient evidence existed to proceed with criminal charges.
They maintained that the High Court was correct in refusing to quash the FIR.

Supreme Court’s Key Observations

1. Civil Dispute Given Criminal Color

“The dispute herein, which forms the genesis of the criminal proceedings initiated by Respondent No. 2, is entirely civil in nature. The issue of whether the registered sale deed is forged and fabricated is a matter for the civil court to decide.”

2. Filing of FIR After Civil Suit Indicates Malicious Intent

The Court noted that the complainant filed the criminal case only after the appellants initiated a civil suit.
The sequence of events suggested an attempt to pressurize the appellants rather than a genuine criminal offense.

3. No Prima Facie Case for Criminal Charges

“An attempt has been made by the complainant to shroud a civil dispute with a cloak of criminality. The chain of sale deeds produced by the appellants contain identical descriptions of the property, yet criminal action has been pursued selectively.”

4. High Court Should Have Quashed Proceedings

“The High Court ought to have quashed the criminal proceedings when it was evident that the dispute was civil and the appropriate remedy was already being pursued.”

Final Verdict

The Supreme Court quashed the criminal proceedings and ruled:

“The impugned order is set aside, and the entire criminal proceedings arising out of FIR No. 375/2022 are quashed. This order shall not affect the pending civil suit, which shall be decided in accordance with the law.”

Conclusion

The Supreme Court’s ruling reinforces key legal principles:

Criminal law should not be misused for civil disputes – Property disputes must be addressed in civil courts.
Sequence of legal proceedings matters – Filing an FIR after losing civil litigation can indicate abuse of process.
Judicial caution in property-related criminal cases – Courts must ensure that criminal law is not weaponized.

This decision prevents harassment through criminal prosecution in genuine property disputes and ensures that such cases remain within the domain of civil law.

Petitioner Name: Dr. Sonia Verma & Anr..
Respondent Name: The State of Haryana & Anr..
Judgment By: Justice Vikram Nath, Justice Satish Chandra Sharma.
Place Of Incident: Bawal, Rewari, Haryana.
Judgment Date: 07-03-2024.

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