Summary and Analysis of Urmila Devi vs. Balram & Another

1. Heading 

Case Title: Urmila Devi & Others (Appellants) vs. Balram & Another (Respondents)
Court: Supreme Court of India
Case No.: Criminal Appeal No. 3300 of 2025 (Arising out of SLP (Cri.) No. 10251 of 2019)
Judges: Justice B.V. Nagarathna and Justice K.V. Viswanathan
Date: July 31, 2025

2. Related Laws and Sections

The judgment revolves around the following legal provisions:

• Indian Penal Code (IPC), 1860:
  Section 419: Cheating by personation.
  Section 420: Cheating and dishonestly inducing delivery of property.
  Section 467: Forgery of valuable security, will, etc.
  Section 468: Forgery for the purpose of cheating.
  Section 471: Using a forged document as genuine.

• Code of Criminal Procedure (CrPC), 1973:
  Section 482: Inherent powers of the High Court to quash criminal proceedings to prevent abuse of process or secure justice.

3. Basic Judgment Details

• Background:
  The dispute arose from a will executed by Shri Ram Baksh Dubey (testator) in 1993, bequeathing his property to his four daughters-in-law (appellants) to prevent his third son, Ashish Kumar, from wasting the estate.
  Ashish Kumar sold his share to Respondent No. 1 (Balram) via a registered sale deed in 1994.
  The appellants, unaware of the sale, secured a mutation order in 1994 based on the will.
  Respondent No. 1 filed a criminal complaint in 2001, alleging forgery of the will to circumvent the sale deed.

• High Court’s Decision:
  The Allahabad High Court dismissed the appellants’ plea to quash the criminal complaint, holding that the allegations prima facie disclosed offences under Sections 419, 420, 467, 468, and 471 IPC.

• Supreme Court’s Decision:
  Quashed the criminal proceedings, ruling that the complaint was a misuse of the legal process to settle a civil dispute.

4. Explanation of the Judgment

Key Issues

1. Whether the criminal complaint against the appellants disclosed offences under IPC Sections 419, 420, 467, 468, and 471?

2. Whether the High Court erred in not quashing the proceedings under Section 482 CrPC?

Supreme Court’s Analysis

• No Prima Facie Offence:
  The Court found no evidence of cheating, forgery, or dishonest intent by the appellants. They were mere legatees under the will and had no role in its creation.
  The allegations were based on speculation, not concrete proof.

• Abuse of Process:
  The criminal complaint was filed belatedly (7 years after mutation, 4 years after civil interim order) with an ulterior motive to pressurize the appellants in a civil dispute.
  Reliance was placed on precedents like State of Haryana v. Bhajan Lal and Madhavrao Scindia, which emphasize quashing proceedings where criminal prosecution is used for harassment or oblique motives.

• Civil vs. Criminal Nature:
  The dispute was inherently civil (property rights) but given a "cloak of criminal offence" (per R.K. Vijayasarathy).
  The will’s validity or the sale deed’s legality should be decided in civil courts, not criminal proceedings.

Conclusion

• The Supreme Court set aside the High Court’s order and quashed the criminal complaint, holding:
  No ingredients of the alleged offences were made out.
  Continuation of proceedings after 20 years would serve no purpose.
  Observations would not affect any pending civil proceedings.

5. Final Outcome

• Criminal proceedings quashed.

• Appeal allowed.

Significance: The judgment reinforces the judiciary’s role in preventing misuse of criminal law in civil disputes and upholds the principles of justice and fairness.