The Supreme Court has quashed an FIR related to a dispute over reimbursement for work completed under a contract, noting that the matter was essentially civil in nature. The Court strongly criticized the growing trend of litigants misusing criminal proceedings and police intervention to settle civil disputes, reaffirming that such attempts undermine the proper use of legal remedies.
The complainant, a contractor, resumed work on a project after receiving assurances of payment from the accused. He submitted bills to Bharat Udyog Limited’s Project Manager and, based on these assurances, sold his personal assets to cover labour and material costs. He later alleged that he was cheated of ₹5.11 crore. An FIR was registered based on his complaint. When the quashing and criminal petitions were dismissed by the lower courts, the accused approached the Supreme Court.
The Division Bench of Justice Vikram Nath and Justice Sandeep Mehta stated, “This Court has time and again come down heavily on the attempts of the over-zealous litigants in trying to settle their civil disputes by misusing the police machinery and resorting to criminal proceedings. A gainful reference in this regard may be made to a decision of three-judge bench of this Court in Inder Mohan Goswami v. State of Uttaranchal, 12 which involved a contractual dispute among the parties wherein a part payment had been made to the complainant by the accused. This Court, while exercising jurisdiction under Article 136 of the Constitution of India, quashed the FIR/criminal proceedings.’
The Court observed that the complainant’s claim was for reimbursement of dues related to work done under a contract, which is essentially a commercial and civil dispute. It noted that the complainant appeared to have misused the police machinery to recover money, as the complaint did not disclose any offence warranting an FIR.
The Court also found that allegations of forged signatures by the complainant’s engineers were not supported by the investigation. Concluding that continuing the FIR proceedings would amount to an abuse of the court’s process, the Bench allowed the appeal and quashed the FIR.
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