Read Full Judgment: The State of Madhya Pradesh v. Shilpa Jain & Ors
In the case of The State of Madhya Pradesh v. Shilpa Jain & Ors., Criminal Appeal Nos. 1565-1567 of 2024 arose from a common order of the High Court of Madhya Pradesh quashing a First Information Report (FIR) and related criminal proceedings. The FIR, filed by the Tehsildar, Khategaon, alleged fraudulent sale transactions of government land, leading to charges under various sections of the Indian Penal Code.
The factual background revealed a longstanding dispute over a property in Dewas, Madhya Pradesh, between the Nagar Palika (Original Plaintiff) and the Respondents. Despite initial civil litigation, subsequent criminal proceedings emerged after investigations into fraudulent land transactions.
The High Court quashed the FIR and related proceedings, citing the inability of the state to prove title over the disputed property. It also emphasized the civil nature of the dispute and reliance on past judgments to justify quashing the FIR under Section 482 of the Criminal Procedure Code (CrPC).
The Appellant contended that the High Court’s premise regarding title ownership was erroneous, as previous court orders affirmed state ownership of the property. They argued that the seriousness of the allegations warranted continuation of the criminal proceedings.
On the other hand, the Respondents argued that the dispute was civil in nature and cited subsequent revenue proceedings that allegedly favored them, claiming title ownership over the property.
The Supreme Court scrutinized the High Court’s decision and legal principles governing the exercise of jurisdiction under Section 482 of the CrPC. It emphasized that revenue records do not establish title, and questions of title can only be resolved by a civil court.
The Court concluded that the High Court erred in assuming the lack of state title over the property and in quashing the FIR solely on civil dispute grounds. It held that the allegations in the FIR warranted criminal investigation, rejecting the argument that the dispute was purely civil.
Therefore, the Supreme Court allowed the appeals, setting aside the High Court’s order and directing the state to proceed with the criminal investigation. It clarified that its observations did not prejudice any subsequent criminal proceedings.
