Sunday, 25 February 2024

Supreme Court: Police Must Exercise Heightened Caution When Drawn Into Dispute Involving Unethical Transactions

 As parting suggestions, it becomes imperative to

state that the police should exercise heightened

caution when drawn into dispute pertaining to

such unethical transactions between private

parties which appear to be prima facie

contentious in light of previous inquiries or

investigations. The need for vigilance on the part

of the police is paramount, and a discerning eye

should be cast upon cases where unscrupulous

conduct appears to eclipse the pursuit of justice.

This case exemplifies the need for a circumspect

approach in discerning the genuine from the

spurious and thus ensuring that the resources of

the state are utilised for matters of true societal

import. {Para 15}

16. For all the reasons recorded above, we are of the

view that such criminal prosecution should not

be allowed to continue where the object to lodge

the FIR is not for criminal prosecution and for

punishing the offender for the offence committed

but for recovery of money under coercion and

pressure and also for all the other reasons

stipulated above.

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. OF 2024

DEEPAK KUMAR SHRIVAS & ANR. Vs STATE OF CHHATTISGARH

Author: VIKRAM NATH, J.

Citation: 2024 INSC 117.

1. Leave granted.

2. As a law enforcement agency, the police force

shoulders the vital responsibility of preserving

public order, guarding social harmony, and

upholding the foundations of justice. However,

the current case, full of counter-accusations of

financial impropriety and broken promises,

highlights the complex matters that occasionally

make their way into the hands of the police force.

Beyond the immediate contours of the case, a

broader question emerges regarding the

balancing of interests that ought to be done

between addressing unscrupulous private

grievances and safeguarding public interests.

From the counter-allegations levelled against

each other between the parties in the present

case, it becomes evident that the police finds

itself entangled in the irrelevant and trivial

details of such unethical private issues, diverting

the resources away from the pursuit of more

consequential matters. The valuable time of the

police is consumed in investigating disputes that

seem more suited for civil resolution. This

underscores the need for a judicious allocation of

law enforcement resources, emphasizing the

importance of channelling their efforts towards

matters of greater societal consequence.

3. By means of this appeal, challenge is to the

correctness of the judgment and order dated

11.07.2023 passed by the Division Bench of the

High Court of Chhattisgarh in WPCR No.703 of

2022 dismissing the writ petition of the appellant

for quashing the criminal proceedings arising out

of FIR bearing Crime No.248 of 2022.


4. Relevant facts for deciding the present appeal are

as follows:

a) The appellant made a complaint dated

06.04.2021 to the Collector, District Janjgir-

Champa (Chhattisgarh) alleging that the

respondent no.6 (Rajkumari Maravi) had

allured the appellant that she would secure a

job for his brother -Raj Kumar Shivas as she

had good contacts with higher officers and

demanded substantial amount for doing this

favour. The appellant got allured and paid

Rs.80,000/- cash at the first instance. Later

on an additional demand was made and,

according to the complaint made by the

appellant, he has thereafter deposited about

Rs.20,000/- and odd in different bank

accounts, details of which were provided by

respondent no.6. When nothing happened

and no job was provided to his brother, he

approached the respondent no.6 for returning

the money paid by him upon which she

threatened him of false implication and later

on she stopped responding to his calls and

started avoiding him.

b) The Collector apparently referred the said

complaint dated 06.04.2021 to the

Superintendent of Police of the District

Janjgir-Champa for enquiry. The enquiry is

alleged to be entrusted by the Superintendent

of Police to the Station House Officer, Police

Station Shakti, District Janjgir-Champa. The

Station House Officer made detailed enquiries

and also recorded the statements of the

appellant, respondent no.6 and other persons

who were sought to be referred to as witnesses

and ultimately submitted the report to the

Superintendent of Police on 25.07.2021.

c) The report mentioned interesting facts,

according to which, both the parties i.e.

appellant and respondent no.6 were accusing

each other of having extracted money for

securing job for their relatives. As already

stated, the appellant was trying to secure a

job for his brother whereas, according to

respondent no.6, the appellant had taken

about Rs.4 lacs from her for securing a job for

her daughter. In the enquiry it was also found

that when no job was provided by the

appellant to her daughter, the appellant

returned some amount by depositing it in her

bank account. Both the parties had alleged

that false complaints were being made against

each other. Interestingly when in the enquiry

the Station House Officer required the

appellant and respondent no.6 to produce the

relevant documents and also the details of the

call records and recorded conversations, they

failed to provide any such material.

Accordingly, it was recommended that the

complaint deserves to be closed.

5. It appears that thereafter the respondent no.6

was successful in lodging an FIR against the

appellant on 27.07.2022, a copy of which is filed

as Annexure P-3. According to the contents of

the FIR, an amount of Rs.4 lacs has been taken

by the appellant and his brother, the other coaccused,

for providing a job to the daughter of

respondent no.6. The said amount was paid in

April, 2019. The transaction is said to be purely

in cash and there are no bank transactions.

Before registering the FIR in this case also an

enquiry was made and a report was submitted to

the Sub-Divisional Officer, who directed for

registration of an FIR. In this enquiry it was

found that both parties have made allegations

against each other of taking money for providing

a job.

6. The appellant filed a petition under Article 226 of

the Constitution before the High Court of

Chhattisgarh for quashing the FIR and the

proceedings arising therefrom. The said petition

has since been dismissed by the impugned order

giving rise to filing of the present appeal.

7. We have heard learned counsel for the parties.

8. Learned counsel for the appellant submitted that

on the earlier occasion upon a complaint

submitted by the appellant to the Collector of the

district, an enquiry was conducted in which

similar allegations against each other were made

by both the sides which were not found to be

substantiated and, therefore, lodging of the

impugned FIR after about one year of the said

enquiry, is mala fide and an abuse of the process

of law. It was further submitted that the

impugned FIR is a counterblast and has been

maliciously lodged only to resist the appellant

from recovering the amount paid by him to the

respondent no.6. It is also submitted that the

alleged transaction according to the FIR is of

April, 2019 whereas the FIR has been lodged in

July, 2022 after more than three years and,

therefore, on the ground of delay, the alleged FIR

deserves to be quashed.

9. On the other hand, learned counsel for the State

of Chhattisgarh as also learned counsel for the

respondents have submitted that a cognizable

offence was disclosed in the FIR and as such the

High Court has rightly dismissed the petition; the

investigation must be allowed to continue and if

ultimately the police report is submitted under

section 173(2) Criminal Procedure Code, 1973

finding the appellant prima facie guilty of the

charge on the basis of the evidence collected

during the investigation, the appellant would

have adequate remedy of assailing the charge

sheet and also claiming discharge at the stage of

framing of charges. There is no justification for

scuttling the investigation which may ultimately

not only deprive the respondent no.6 of her hardearned

money but also the offence committed by

the appellant would go unpunished. It was also

submitted that it was a clear case of cheating as

the appellant had deceitfully induced the

respondent no.6 to provide a job to her daughter

by taking huge amount of money and thereafter

neither providing the job nor returning the

money.

10. Having heard learned counsel for the parties, we

proceed to analyse the material on record and

submissions advanced by the parties.

11. In the complaint made by the appellant in 2021

to the Collector an enquiry has been made by the

Station House Officer of the Police Station

concerned in which the fact that the respondent

no.6 had stated that she had paid Rs.4 lacs to

the appellant for providing a job to her daughter

was recorded. This clearly means that

respondent no.6 was well aware of the complaint

made by the appellant and in the enquiry her

statement had been actually recorded. The

respondent no.6 therefore cannot raise a plea

that she had no knowledge of the complaint made

by the appellant. Despite the same she did not

lodge any complaint against the appellant and


his brother and waited for more than a year to

lodge the FIR in July, 2022.

12. According to the allegations made in the FIR, the

job was to be provided by the appellant within

three months of April, 2019 i.e. by July, 2019.

However, the respondent no.6 did not take any

action for a period of three years till July, 2022

when the FIR in question was lodged. Thus, the

FIR suffers from a serious delay of three years

which is totally unexplained.

13. A reading of the entire material on record clearly

reflects that it was totally an unlawful contract

between the parties where money was being paid

for securing a job in the government

department(s) or private sector. Apparently, a

suit for recovery could not have been filed for the

said purpose and even if it could be filed, it could

be difficult to establish the same where the

payment was entirely in cash. Therefore, the

respondent no.6 found out a better medium to

recover the said amount by building pressure on

the appellant and his brother by lodging the FIR.

Under the threat of criminal prosecution, maybe


the appellant would have tried to sort out and

settle the dispute by shelving out some money.

14. In conclusion, certain key observations from the

factual matrix warrant a closer reflection. Prima

facie, the conduct exhibited by the parties

involved appears tainted with suspicion, casting

a shadow over the veracity of their claims. The

report from the previous inquiry reflects a

convoluted landscape and unveils a trail of

unethical, maybe even criminal, behaviour from

both parties. The unexplained inordinate delay in

bringing these allegations to the police’s

attention despite knowledge of previous inquiry,

raises even more doubts and adds a layer of

scepticism to the authenticity of the claims. The

facts stated, as well as the prior inquiry, reveal a

shared culpability between the parties, indicative

of a complex web of deceit, and unethical

transactions where even civil remedies may not

be sustainable. Thus, the object of this dispute,

manifestly rife with mala fide intentions of only

recovering the tainted money by coercion and

threat of criminal proceedings, cannot be allowed

to proceed further and exploit the time and

resources of the law enforcement agency.

15. As parting suggestions, it becomes imperative to

state that the police should exercise heightened

caution when drawn into dispute pertaining to

such unethical transactions between private

parties which appear to be prima facie

contentious in light of previous inquiries or

investigations. The need for vigilance on the part

of the police is paramount, and a discerning eye

should be cast upon cases where unscrupulous

conduct appears to eclipse the pursuit of justice.

This case exemplifies the need for a circumspect

approach in discerning the genuine from the

spurious and thus ensuring that the resources of

the state are utilised for matters of true societal

import.

16. For all the reasons recorded above, we are of the

view that such criminal prosecution should not

be allowed to continue where the object to lodge

the FIR is not for criminal prosecution and for

punishing the offender for the offence committed

but for recovery of money under coercion and

pressure and also for all the other reasons

stipulated above.

17. We, accordingly allow this appeal, and after

setting aside the impugned order passed by the

High Court, quash the entire proceedings arising

out of FIR 248 of 2022.

……………………………………J.

(VIKRAM NATH)

……………………………………J.

(SATISH CHANDRA SHARMA)

NEW DELHI

FEBRUARY 19, 2024

Print Page

No comments:

Post a Comment