Legal Review and Analysis of Anukul Singh vs State of Uttar Pradesh & Anr 2025 INSC 1153

1. Name of the Judgment

Anukul Singh vs. State of Uttar Pradesh & Anr.
Criminal Appeal No. 4250 of 2025 (Arising out of SLP (Crl.) No. 2682 of 2020)
Decided on: September 24, 2025
Judges: Justice R. Mahadevan and Justice B.V. Nagarathna

Citation:
Anukul Singh vs. State of Uttar Pradesh & Anr., (2025) INSC 1153, Criminal Appeal No. 4250 of 2025 (Supreme Court of India).

2. Relevant Laws and Sections

• Code of Criminal Procedure, 1973 (CrPC) – Section 482 (Inherent powers of the High Court to prevent abuse of the process of any court or to secure the ends of justice).

• Indian Penal Code, 1860 (IPC) – Sections 420 (Cheating), 467 (Forgery of valuable security, will, etc.), 468 (Forgery for purpose of cheating).

• Negotiable Instruments Act, 1881 – Section 138 (Dishonour of cheque).

• Precedents Referenced:
  State of Haryana vs. Bhajan Lal, 1992 Supp (1) SCC 335
  Indian Oil Corporation vs. NEPC India Ltd., (2006) 6 SCC 738
  Suryalakshmi Cotton Mills Ltd. vs. Rajvir Industries Ltd., (2008) 13 SCC 678
  Inder Mohan Goswami vs. State of Uttaranchal, AIR 2008 SC 251
  Shailesh Kumar Singh vs. State of Uttar Pradesh, 2025 INSC 869

3. Basic Details of the Case

• Appellant: Anukul Singh (Accused in the FIR)

• Respondents: State of Uttar Pradesh and the Complainant (Respondent No. 2)

• Nature of Dispute: Appeal against the Allahabad High Court's order that refused to quash an FIR and consequent criminal proceedings.

• Subject FIR: Crime No. 47 of 2003, registered at PS Bilari, Moradabad, for offences under Sections 420, 467, and 468 IPC.

• Supreme Court’s Decision: Allowed the appeal and quashed the FIR and all consequent proceedings.

4. Core Principle and In-Depth Legal Analysis

The Central Issue

Whether the criminal proceedings initiated against the appellant should be quashed under Section 482 CrPC because the allegations, even if taken as true, disclose a purely civil dispute and the FIR was a mala fide counterblast, making the continuation of prosecution an abuse of the judicial process.

Factual Matrix and Genesis of the Dispute

The case originated from a property dispute. The appellant's father purchased land in 2000. The appellant's opposition to the use of this land for 'Qurbani' (animal sacrifice) by local religious figures led to alleged harassment by the local administration and police. This backdrop is critical, as the appellant claims that a series of eight FIRs, including the present one, were foisted on him as a counterblast after he legally initiated actions against the complainant, including an earlier FIR and a case under the Negotiable Instruments Act for cheque dishonour.

The Supreme Court's Legal Reasoning

A. Revisiting the Scope of Section 482 CrPC
The Court began by reiterating the well-settled principles governing the High Court's inherent powers under Section 482. It emphasized that while this power is wide, it must be exercised sparingly and with caution. The Court referred to the landmark guidelines in State of Haryana vs. Bhajan Lal, which outline specific categories where quashing is justified. The Court clarified that the objective is to prevent abuse of process and ensure that criminal law is not used as a tool for harassment, not to conduct a mini-trial on disputed facts.

B. Distinguishing Civil Wrong from Criminal Offence
The core of the Court's analysis was to determine the true nature of the dispute. The allegations in the FIR pertained to a loan transaction, an agreement to sell, and dishonoured cheques. The Court held that these allegations, in their entirety, pertained to a commercial/contractual transaction. The essence of the complaint was the non-repayment of a loan, which is a civil wrong. The Court stressed that for an offence of cheating (Section 420 IPC) to be made out, the complainant must demonstrate a dishonest intention at the inception of the agreement. The FIR lacked any such allegation. Similarly, the forgery charges (Sections 467, 468 IPC) were not substantiated by the basic facts presented.

C. Establishing Mala Fides and Abuse of Process
The Court found compelling evidence that the FIR was malicious:

• Retaliatory Nature: The present FIR was registered months after the appellant had filed a case under Section 138 of the N.I. Act against the complainant. The complainant was subsequently convicted in that case. This timing strongly suggested the FIR was a counterblast.

• Pattern of Harassment: The registration of eight FIRs against the appellant in a short span, against the backdrop of the property dispute, indicated a concerted effort to misuse the criminal justice system to harass him.

• Application of Bhajan Lal Categories: The Court concluded that the case squarely fell under Category (1) (allegations do not prima facie constitute an offence) and Category (7) (proceedings manifestly attended with mala fide and ulterior motive) of the Bhajan Lal guidelines.

D. Judicial Disapproval of Criminalizing Civil Disputes
Relying on precedents like Indian Oil Corporation vs. NEPC India Ltd. and Shailesh Kumar Singh vs. State of Uttar Pradesh, the Court deprecated the growing tendency to give a criminal colour to civil disputes, especially contractual or commercial ones, to pressurize the opposite party. It underscored that criminal courts are not a substitute for civil forums for debt recovery.

5. Final Outcome

The Supreme Court allowed the appeal. It set aside the impugned order of the High Court dated October 22, 2019. Consequently, it quashed the following:

• FIR No. 47 of 2003 dated February 5, 2003, registered at P.S. Bilari, District Moradabad.

• The consequential charge sheet and all proceedings emanating therefrom.

The Court clarified that its decision would not preclude the parties from pursuing any civil remedies available to them in law.

6. MCQs Based on the Judgment

Q 1. In Anukul Singh vs. State of Uttar Pradesh, the Supreme Court quashed the criminal proceedings primarily on the ground that?

A. The investigation conducted by the police was procedurally flawed.
B. The complainant had already been convicted in a related case.
C. The allegations in the FIR disclosed a civil dispute and the prosecution was malicious.
D. The High Court had failed to consider the appellant's defence evidence during the trial.

Correct Answer: C
Explanation: The core of the judgment is that the FIR's allegations pertained to a civil/commercial dispute (loan repayment) and lacked the essential ingredients of a criminal offence. Furthermore, the circumstances indicated the FIR was a mala fide counterblast, making it an abuse of the judicial process.

Q 2. According to the judgment, which of the following is a key legal principle for quashing an FIR under Section 482 CrPC as per the guidelines in State of Haryana vs. Bhajan Lal?

A. The High Court must always wait for the trial to conclude.
B. Quashing is justified if the allegations, even if accepted as true, do not prima facie constitute a cognizable offence.
C. The accused must first surrender before seeking quashing.
D. The credibility of witness statements must be evaluated in a quashing petition.

Correct Answer: B
Explanation: The judgment heavily relies on Category (1) from the Bhajan Lal case, which allows quashing when the allegations in the FIR, taken at face value, do not make out a case against the accused. The Court found this applicable as the dispute was essentially civil in nature.