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Supreme Court Declines to Quash Criminal Case Against Contractor, Says Dispute Not "Purely Civil" Despite No-Dues Certificate Claims

Vivek G.

Rocky v. State of Telangana & Anr. Supreme Court refuses to quash cheating case against contractor, ruling dispute isn’t purely civil and must proceed to trial despite No-Dues Certificate claims.

Supreme Court Declines to Quash Criminal Case Against Contractor, Says Dispute Not "Purely Civil" Despite No-Dues Certificate Claims

In a hearing that saw sharp exchanges and deep dives into decade-old construction transactions, the Supreme Court on Thursday dismissed contractor Rocky’s appeal seeking to quash criminal proceedings arising from a long-pending business dispute with a Hyderabad-based builder. The bench-hearing the matter for over an hour-made it clear that the criminal case could not simply be brushed aside as a civil disagreement, despite the contractor’s repeated insistence that the allegations were nothing more than a business fallout.

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Background

The conflict traces its roots to construction work done between 2008 and 2010. Both sides had once signed a No-Dues Certificate in June 2010, but the relationship soon soured, leading to cross-allegations and, ultimately, an FIR in 2015 accusing Rocky of cheating, wrongful confinement, and criminal intimidation.

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The High Court previously quashed charges of criminal breach of trust (Section 406 IPC) but allowed proceedings for cheating (Section 420 IPC), wrongful confinement 420, 344 and 506to continue. Dissatisfied, the contractor moved the Supreme Court seeking a clean slate.

Court’s Observations

From the outset, the bench seemed unconvinced by the attempt to paint the case as a mere contractual misunderstanding. One of the judges remarked during the hearing, “The presence of a civil dispute does not automatically exclude criminal liability. Both can exist side by side.”

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The Court also took note of four witness statements collected during investigation and found no reason to disregard them at this early stage. As the judgment records, “These assertions cannot, at this stage, be regarded as inherently improbable or absurd.”

Rocky’s reliance on the No-Dues Certificate-argued as proof that nothing was owed-didn’t carry much weight. The complainant claims the document is fabricated, a dispute the Court said can only be decided at trial.

“The bench observed, ‘When the very authenticity of a document is seriously disputed, it cannot form the basis for quashing proceedings at the threshold.’”

The Court also reiterated limits on the High Court’s power to quash criminal charges, referring to the Bhajan Lal categories and the structured four-step test laid out in earlier judgements. None of these parameters, the bench held, were met in this case.

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Decision

Concluding its analysis, the Supreme Court upheld the Telangana High Court’s decision and refused to quash proceedings for cheating, wrongful confinement, and intimidation.

The judges noted, “We find no illegality or perversity in the High Court’s refusal to quash. The allegations require a full trial.”

With that, the appeal was dismissed, leaving the contractor to face trial before the Hyderabad magistrate’s court.

Case Title: Rocky v. State of Telangana & Anr.

Case Number: Criminal Appeal (arising out of SLP (Crl.) No. 11151 of 2025)

Case Type: Criminal Appeal (Challenge to refusal to quash criminal proceedings under Section 482 CrPC)

Decision Date: December 04, 2025

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