The Supreme Court on Tuesday brought relief to two Agra residents caught in a maze of criminal proceedings arising from the same dispute, questioning the need for custodial action after the police itself found no substance in the allegations. The case involved multiple complaints filed across different states, all stemming from a refund dispute that had taken a criminal turn.
Background of the Case
The petition was filed by Smt. Shalini Bhateja and another, who were named as accused in an FIR registered in June 2025 at Tajganj Police Station in Agra. The FIR alleged cheating and conspiracy in relation to a refund that the complainant claimed had not been returned.
Earlier, the petitioners had approached the Allahabad High Court seeking quashing of the FIR, arguing that the complaint was motivated and purely civil in nature. The High Court declined to interfere and directed them to appear before the trial court, granting them liberty to seek bail.
Challenging this, the petitioners moved the Supreme Court, pointing out that the same complainant had initiated three criminal proceedings in different jurisdictions based on identical facts.
During the hearing, the court was informed that one complaint had been filed before a Delhi court, another before a magistrate in Agra, and the third resulted in the FIR under challenge. Two of these proceedings had already stalled-one was stayed by a sessions court, while the other was withdrawn after the police reported that the dispute appeared civil.
The State also confirmed that investigation in the Agra FIR had concluded and a final report was submitted, stating that the allegations could not be substantiated.
Court’s Observations
The bench noted that once a chargesheet had been filed concluding that no offence was made out, there was no justification for taking the accused into custody.
“The proceedings in the other cases need not continue,” the court observed, while directing closure of the parallel complaints pending in Delhi and Agra. The judges made it clear that continuation of multiple criminal cases on the same cause of action would serve no purpose.
The court also allowed an application filed by the Interim Resolution Professional appointed by the NCLT, permitting representation of the complainant through him.
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Final Decision
Disposing of the Special Leave Petition, the Supreme Court directed that the petitioners appear before the jurisdictional court within one month. Upon appearance, they are to be granted bail on the same day, subject to conditions deemed appropriate by the trial court.
The court further ordered that charges be read over immediately and directed the accused to cooperate in the expeditious trial of the case. It clarified that the complainant, through the Interim Resolution Professional, would be free to summon relevant witnesses during the trial.
With these directions, the proceedings before the Supreme Court were formally closed on January 6, 2026.
Case Title: Smt. Shalini Bhateja & Anr. vs State of Uttar Pradesh & Ors.
Case No.: SLP (Crl.) No. 11375 of 2025
Case Type: Criminal – Special Leave Petition
Decision Date: January 6, 2026
