The Punjab and Haryana High Court has refused to quash an FIR registered in an alleged land fraud case involving disputed property transactions in Mohali, holding that an accused cannot seek quashing of criminal proceedings after repeatedly failing to secure anticipatory bail and avoiding investigation.
Justice Sumeet Goel dismissed the plea filed by Kuldeep Singh and imposed costs of ₹5,000, observing that the petition was an attempt to bypass earlier judicial orders.
Background of the Case
The case arose from FIR No. 01 dated January 10, 2026, registered at Police Station NRI District, Mohali, Punjab under provisions of the Bharatiya Nyaya Sanhita relating to cheating, forgery, conspiracy and related offences.
According to the complaint, NRI complainant Jaskirat Singh Tiwana alleged that Kuldeep Singh and others prepared a forged agreement to sell regarding agricultural land owned by his father. The complainant claimed the agreement was fabricated as part of a conspiracy to illegally grab the property.
Kuldeep Singh, however, argued before the High Court that the dispute was purely civil in nature. He contended that a genuine agreement to sell had been executed in November 2024 and that he had already paid ₹28 lakh as earnest money. The petitioner claimed he later filed a civil suit for specific performance after the sale deed was allegedly not executed.
The petitioner further alleged that the criminal case was initiated only to pressure him in the ongoing civil dispute.
Earlier Bail Proceedings
The High Court noted that Kuldeep Singh’s anticipatory bail plea had already been dismissed on February 4, 2026. His challenge before the Supreme Court through a Special Leave Petition was also rejected on February 16, 2026.
The Court recorded that despite dismissal of his anticipatory bail plea by both courts, the petitioner neither surrendered nor joined the investigation.
Justice Sumeet Goel observed that once anticipatory bail had been rejected on merits and the order had attained finality, seeking quashing of the FIR on the same facts without any major change in circumstances was legally unsustainable.
“The petitioner cannot be permitted to achieve indirectly what he could not secure directly,” the Court observed while criticising the attempt to reopen issues already examined in earlier proceedings.
The Court further remarked that entertaining such pleas would encourage speculative litigation and weaken judicial discipline.
In strong observations, the Bench said repeated attempts to seek relief on substantially similar grounds amounted to misuse of the legal process. The Court termed the strategy a “hit and try methodology” and warned against litigants repeatedly approaching courts after adverse orders.
Justice Goel also clarified that the High Court’s power to quash criminal proceedings under Section 528 BNSS is extraordinary in nature and should be exercised sparingly. The Court said such relief cannot be granted merely because a parallel civil dispute exists.
Dismissing the petition, the High Court imposed costs of ₹5,000 on the petitioner and directed that the amount be deposited before the Chief Judicial Magistrate, Mohali within four weeks. The Court further directed that the amount be transferred to the District Legal Services Authority, Mohali.
The Bench clarified that observations made in the order would not affect the merits of the pending criminal proceedings or trial.
Case Details
Case Title: Kuldeep Singh v. State of Punjab and Others
Case Number: CRM-M-12541-2026
Judge: Justice Sumeet Goel
Decision Date: May 6, 2026
