Supreme Court Quashes Criminal Proceedings in Property Dispute: A Landmark Judgment on Misuse of Legal Process

The case of P.M. Lokanath and Others vs. State of Karnataka and Another is a crucial judgment where the Supreme Court of India quashed criminal proceedings that were initiated with mala fide intentions. This case underscores the judiciary’s role in preventing the misuse of criminal law to settle civil disputes.

The appellants, P.M. Lokanath and others, were involved in a longstanding property dispute with Respondent No. 2. The issue revolved around a property located at Subbanna Char Lane, 2nd Cross, Cottonpet, Bangalore, which the appellants had inherited from their predecessor, Smt. K. Janakamma. Respondent No. 2, along with his siblings, challenged the appellants’ ownership and allegedly attempted to encroach upon the property.

Background of the Case

To protect their rights, the appellants filed multiple civil suits:

O.S. No. 11107/2016: A suit seeking a permanent injunction against Respondent No. 2 and his siblings to prevent them from interfering with the property.
O.S. No. 1943/2008: A suit for the declaration of ownership of the property.

In the first case, the Principal City Civil and Sessions Judge, Bangalore, granted a temporary injunction in favor of the appellants, restraining Respondent No. 2 and his family from encroaching upon the property.

Despite this, Respondent No. 2 filed an FIR under Sections 448 and 506 of the Indian Penal Code (IPC), alleging that the appellants had threatened him with dire consequences if he did not withdraw the civil suits. Subsequently, a chargesheet was filed, and the IIIrd Additional Chief Metropolitan Magistrate (ACMM), Bangalore, took cognizance of the case and issued summons to the appellants.

Arguments Presented Before the Court

Petitioner’s Arguments

Senior Counsel Shri Anand Sanjay M. Nuli, representing the appellants, contended that:

The criminal proceedings were initiated with mala fide intentions.
The allegations in the FIR were false and intended to harass the appellants.
Respondent No. 2 had a history of filing false cases against the appellants.
Since the appellants had themselves filed civil suits, there was no logical reason for them to threaten Respondent No. 2.
The continuation of the criminal proceedings was an abuse of legal process.

Respondent’s Arguments

Shri V.N. Raghupathy, counsel for the State of Karnataka, opposed the appeal, arguing that:

The FIR was valid as it contained specific allegations of threats and criminal trespass.
The police had conducted a fair investigation before filing the chargesheet.
The matter needed to be examined through a proper trial rather than being quashed at the preliminary stage.

Supreme Court’s Analysis and Observations

The Supreme Court observed that the criminal allegations lacked merit and appeared to be motivated by the ongoing civil dispute.

“When Respondent No. 2 has not filed any suit, there is no question of the appellants threatening him with dire consequences if he does not withdraw the suit.”

The Court also referred to the precedent set in State of Haryana v. Bhajan Lal, which enumerates instances where criminal proceedings can be quashed, including:

When the allegations in the FIR do not constitute an offense.
When the FIR is manifestly absurd or inherently improbable.
When the criminal proceedings are initiated with an ulterior motive for personal vengeance.

Referring to these principles, the Court held:

“The present case squarely falls under points 1, 3, 5, and 7 of paragraph 102 of Bhajan Lal’s judgment. The allegations in the FIR are inherently improbable and intended to harass the appellants.”

Verbal Arguments of the Court

While delivering the judgment, the Supreme Court made several key observations:

“A criminal proceeding cannot be used as a tool for arm-twisting or pressurizing parties engaged in civil litigation. The courts must be vigilant in preventing the misuse of the criminal justice system.”

“When there is a pending civil dispute, and the allegations in the FIR appear to be fabricated, the courts must intervene to prevent harassment.”

“The allegations in the FIR are so absurd that no prudent person could conclude that there is sufficient ground for proceeding against the appellants.”

Final Judgment and Conclusion

Based on these findings, the Supreme Court allowed the appeal, stating:

“The appeal is accordingly allowed. The impugned judgment and order dated 14th November 2013 passed by the learned Single Judge of the High Court of Karnataka at Bangalore is quashed and set aside. The chargesheet registered as C.C. No. 29027/2010 before the Court of IIIrd Additional Chief Judicial Magistrate, Bangalore, the order dated 26th June 2010 issuing summons to the appellants, and the subsequent proceedings arising therefrom are also quashed and set aside.”

The judgment sets an important precedent in safeguarding individuals from malicious criminal proceedings arising out of civil disputes. It reaffirms that criminal law should not be misused to settle personal scores and emphasizes the need for judicial scrutiny in such matters.

Petitioner Name: P.M. Lokanath and Others.
Respondent Name: State of Karnataka and Another.
Judgment By: Justice B.R. Gavai, Justice K. Vinod Chandran.
Place Of Incident: Bangalore, Karnataka.
Judgment Date: 05-02-2025.

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