Legal Review and Analysis of Smt Shalini Bhateja & Anr vs The State of UP & Ors 2026 INSC 28

Case Synopsis

Case: Smt. Shalini Bhateja & Anr. vs The State of U.P. & Ors., (2026) INSC 28.

Synopsis :  This judgment underscores the pragmatic role of the Supreme Court in terminating criminal proceedings where the investigative authority itself has found the allegations baseless. It provides a roadmap to efficiently conclude vexatious litigation involving multiple parallel cases, balancing the liberty of the accused with procedural formalities and the rights of a complainant entity in insolvency.

1. Heading of the Judgment

Case Name: Smt. Shalini Bhateja & Anr. vs The State of U.P. & Ors.
Citation: 2026 INSC 28 (Special Leave Petition (Crl.) No.11375 of 2025)
Court: Supreme Court of India
Bench: Hon'ble Mr. Justice K. Vinod Chandran and Hon'ble Mr. Justice Ahsanuddin Amanullah
Date of Judgment: January 06, 2026

2. Related Laws and Sections

The judgment deals with the following legal provisions and principles:

• Section 482 of the Code of Criminal Procedure, 1973 (CrPC): Pertains to the inherent powers of the High Court to prevent abuse of the process of any court or to secure the ends of justice. The petitioners had approached the High Court under this section seeking quashing of the FIR.

• Principles for Quashing FIR: The judgment implicitly engages with the well-established jurisprudence laid down in cases like State of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335), which outlines categories where an FIR can be quashed, including cases that are purely civil in nature given a criminal guise.

• Jurisdiction of the National Company Law Tribunal (NCLT): The judgment notes the involvement of the NCLT and an Interim Resolution Professional (IRP) due to the corporate status of the complainant entity.

3. Basic Judgment Details

A. Facts of the Case

• The Petitioners were accused in FIR No. 396 of 2025 registered at Police Station Taiganj, Agra, alleging cheating and conspiracy. The complaint was filed by Nikhil Garg, representing a corporate entity.

• The Petitioners' case before the High Court was that the dispute was civil in nature (likely concerning a financial transaction or refund) and the FIR was lodged with mala fide intent to harass. The High Court declined to quash the FIR but directed the petitioners to appear before the Trial Court within 60 days, with liberty to seek bail.

• It was revealed that three separate FIRs/complaints had been filed on the same set of facts in different jurisdictions (Agra and Delhi). One had been stayed by a Revision Court, and another was disposed of as "not pressed" after a police report indicated the dispute was civil.

• Crucially, during the pendency of the SLP before the Supreme Court, the investigation in the impugned FIR (No. 396 of 2025) concluded with the filing of a Final Report (Closure Report) stating that the allegations against the accused were not substantiated.

B. Issues Before the Supreme Court

1. Whether to quash the FIR in light of the investigating agency's final report concluding that the allegations were not substantiated?

2. How to deal with the multiplicity of proceedings on the same cause of action across different courts?

3. What procedural directions are necessary to balance the rights of the accused, the complainant (now represented by an IRP due to corporate insolvency), and the interest of justice?

C. Ratio Decidendi (Court's Reasoning)

• Final Report as a Decisive Factor: The Supreme Court took significant note of the Final Report (Closure Report) submitted by the Investigating Officer, which concluded that the allegations were not substantiated. This official finding by the police fundamentally undermined the basis for continuing the criminal prosecution against the petitioners.

• Addressing Multiplicity of Proceedings: The Court, with the consent of the parties, took a holistic view to end the vexatious litigation stemming from the same facts. It directed the closure of the other parallel proceedings (C.C. No.1971 of 2023 in Delhi and C.C. No.19488 of 2025 in Agra) and the disposal of the related Criminal Revision.

• Preventing Needless Custody: Since a chargesheet (based on the Final Report) had been filed and the investigation had exonerative findings, the Court reasoned that there was no justification for taking the petitioners into custody. The appropriate course was to ensure their appearance before the trial court to formally close the case.

• Accommodating the Corporate Complainant's New Status: Recognizing that the corporate complainant was under the NCLT's insolvency process, the Court impleaded the Interim Resolution Professional (IRP) and granted him the right to represent the complainant and summon relevant officials as witnesses, safeguarding the interests of the corporate entity in liquidation.

4. Core Principle of the Judgment 

Pragmatism Over Formality in Terminal Stages

Title: Judicial Prudence at the Crossroads of Investigation and Trial: Terminating Proceedings Upon Investigative Exoneration

Analysis
The core issue addressed by the Supreme Court was not the abstract question of distinguishing civil from criminal disputes, but the concrete and practical question of how to proceed when the state's own investigative machinery, after due process, finds no evidence to support the criminal allegations.

The Court moved beyond the theoretical arguments about the nature of the dispute. Instead, it focused on the current procedural reality: a Closure Report (Final Report) under Section 173 CrPC had been filed. This report represents the formal conclusion of the police investigation, asserting no case is made out. Continuing to compel the accused to face a full trial in such circumstances, especially with parallel vexatious complaints, would itself be an abuse of process.

The judgment demonstrates a pragmatic and outcome-oriented approach. It did not formally quash the FIR under Article 142 or Section 482, which would have required a deeper analysis of merits at the threshold. Instead, it utilized its supervisory jurisdiction to give binding directions that achieve the same just outcome: ensuring the accused are not arrested, streamlining the multiplicity of cases, and fast-tracking the inevitable termination of the case before the trial court. This approach respects the procedural chain (the chargesheet is before the trial court) while preventing any further prejudice to the accused.

The Court also adeptly handled the complication of corporate insolvency by integrating the IRP into the process, ensuring the legal rights of the entity in resolution are not extinguished due to a change in its management status.

5. Final Outcome and Supreme Court Directions

The Supreme Court disposed of the Special Leave Petition with the following binding directions:

1. Closure of Parallel Proceedings:
   C.C. No.19488 of 2025 (Agra) was noted as already disposed of as not pressed.
   C.C. No.1971 of 2023 (Delhi) was directed to stand closed.
   Criminal Revision No. 206 of 2024 (Delhi) was to be disposed of by the Additional Sessions Judge as not pressed.

2. Procedure for the Impugned FIR (No. 396 of 2025):
   The Petitioners were to appear before the jurisdictional trial court within one month.
   Upon appearance, they were to be granted bail immediately on conditions set by the trial court.
   The charges were to be read over on the same day, commencing the trial process.
   The Petitioners were directed to cooperate for the expeditious disposal of the case.

3. Rights of the Complainant:
   The Interim Resolution Professional (IRP) was impleaded as the legitimate representative of the corporate complainant.
   The IRP was entitled to represent the complainant and could summon former officials/directors as witnesses.

6. (MCQs) Based on the Judgment

Question 1: In Smt. Shalini Bhateja & Anr. vs State of U.P., what was the pivotal factual development that most influenced the Supreme Court's decision to grant relief to the accused petitioners?
a) The High Court had granted them liberty to apply for anticipatory bail.
b) The Investigating Officer filed a Final Report (Closure Report) concluding that the allegations against them were not substantiated.
c) The complainant admitted the dispute was purely civil.
d) The petitioners agreed to settle the monetary dispute.

Question 2: The Supreme Court, while disposing of the SLP, gave specific directions regarding multiple cases filed on the same facts. What was the Court's overarching approach?
a) To transfer all cases to the National Company Law Tribunal (NCLT) for consolidated adjudication.
b) To allow all cases to proceed independently to gather maximum evidence.
c) To ensure the closure or formal disposal of the parallel proceedings to prevent multiplicity and harassment.
d) To direct a fresh investigation by a special police team.