A civil dispute does not bar criminal proceedings where the FIR prima facie discloses cognizable offences.

The complainant purchased Plot No. 17/25, Khasra No. 559/1/थ/6, measuring 1,500 sq. ft. at Village Khamtarai, Bilaspur, for ₹18,75,000 on 30 March 2022.

His mutation application was rejected because the land was recorded as “Chote-Bade Jhad Ka Jangal” and allegedly constituted Government land that could not be sold without the Collector’s permission.

He alleged that the vendors and other accused persons misrepresented the ownership of the land and cheated him.

An FIR, Crime No. 759/2025 dated 26 May 2025, was registered at Police Station Sarkanda under Sections 420, 467, 468, 471 and 120-B read with Section 34 IPC.

A consequential charge-sheet, No. 380/2026 dated 19 April 2026, was thereafter filed.

The petitioner sought quashing of the FIR and charge-sheet, asserting that he had merely signed the sale deed as an attesting witness and had no substantive role in the alleged offence.

Whether the FIR and consequential charge-sheet disclosed a prima facie case against the petitioner, notwithstanding his contention that he was merely an attesting witness to the sale deed.

Whether the alleged civil nature of the land-sale dispute justified quashing the criminal proceedings under the High Court’s inherent jurisdiction under Section 482 CrPC.

The Court considered the offences under Sections 420, 467, 468, 471 and 120-B read with Section 34 of the IPC, relating respectively to cheating, forgery, use of forged documents, criminal conspiracy and acts done in furtherance of common intention.

In exercising inherent jurisdiction under Section 482 CrPC, the High Court must ordinarily confine itself to the allegations in the FIR and the prosecution material and should not conduct a mini-trial or assess disputed defence documents.

It relied on Accamma Sam Jacob v. State of Karnataka & Another, 2026 INSC 362, which held that quashing is justified only where the proceedings lack legal foundation, are perverse, or would result in failure of justice; the mere availability of a civil remedy does not bar criminal proceedings where the allegations prima facie disclose a cognizable offence.

The Court also considered the principle in Nishant Agrawal v. State of Chhattisgarh and Pandurang Krishnaji that mere attestation of a document does not, by itself, establish knowledge of or consent to its contents.

The FIR and charge-sheet material prima facie showed that the land was recorded as “Bade Jhad Ka Jangal” and may have been Government land, yet it was represented in the sale deed as belonging to the vendors.

The prosecution further alleged that the petitioner was a partner of S.N. Group, which executed the sale deed, and that he signed the document as an attesting witness despite allegedly knowing the nature and status of the land.

Although mere attestation ordinarily does not establish participation in fraud, the surrounding circumstances and the petitioner’s alleged knowledge prevented the Court from ruling out his involvement at the threshold.

The Court declined to evaluate disputed factual and title issues or to rely on the petitioner’s defence, holding that such matters belonged to investigation and trial.

It further held that the existence of a civil remedy did not extinguish the criminality allegedly disclosed by the FIR and prosecution material.

It also held that the purportedly civil character of the dispute was not a sufficient ground for quashing the criminal proceedings.

Accordingly, the petition seeking quashing of FIR Crime No. 759/2025 and charge-sheet No. 380/2026 was dismissed.