In a sharp rebuke to the misuse of criminal proceedings, the Supreme Court on Tuesday set aside a 22-year-old forgery and cheating case against Moradabad resident Anukul Singh, calling the police action “an abuse of the process of law.” The bench of Justices B.V. Nagarathna and R. Mahadevan ruled that what was essentially a civil property dispute had been “given a criminal colour” by local authorities and private complainants.
Background
The dispute began after Singh’s father purchased over eight hectares of land in Bilari, Moradabad, in 2000. Local cleric Shaher Imam objected, claiming the land was traditionally used for Qurbani (sacrificial rituals). Despite the tehsildar approving the family’s ownership, Singh alleged that he and his relatives faced harassment from politicians and police. Within a single week in 2003, eight FIRs were filed against him, including the present case of alleged forgery and cheating.
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The complainant claimed Singh coerced him into signing an agreement to sell a plot after giving only part of a ₹2 lakh loan and forced him to issue cheques that later bounced. Singh countered that the complaint was a “counterblast” to an earlier cheating case he had filed, where the same complainant was arrested.
Court’s Observations
“The allegations, even if accepted, point only to a civil dispute,” the bench observed. It cited the landmark Bhajan Lal judgment, stressing that criminal law cannot be used to settle personal scores or commercial disagreements. The judges noted the “remarkable coincidence” that the complainant was convicted this January for cheque dishonour in a related case, reinforcing Singh’s claim of vendetta.
The Court criticised the “growing tendency to convert purely civil disputes into criminal cases,” cautioning that such tactics erode faith in the justice system. “Money cannot be recovered by filing an FIR and seeking police help. This amounts to abuse of the process of law,” the order stated.
Decision
Allowing Singh’s appeal, the Supreme Court quashed FIR No. 47 of 2003 and the accompanying charge sheet dated April 16, 2003. “Continuation of such prosecution would amount to an abuse of process,” the bench declared. However, it clarified that the complainant remains free to pursue any civil remedies available under law.
Case: Anukul Singh vs. State of Uttar Pradesh & Another
Citation: 2025 INSC 1153
Case No.: Criminal Appeal No. 4250 of 2025 (arising from SLP (Crl.) No. 2682 of 2020)
Decision Date: 24 September 2025
