A vexatious FIR arising from a civil property dispute may be quashed under Section 482 CrPC.

The complainants alleged that the petitioners had participated in fabricating documents to deprive them of property and that some petitioners had abused them by referring to their caste and threatened or assaulted them. The complaint led to registration of Crime No. 1/2020 for offences under Sections 3(v) and 3(x) of the SC/ST (Prevention of Atrocities) Act, 1989, and Sections 506, 420, 504, 471, 323 and 468 read with Section 34 of the IPC

The petitioners sought quashing under Section 482 CrPC, contending that the complaint arose from a longstanding property dispute and was an abuse of process. They relied on prior sale and revenue proceedings, and on earlier writ, appellate and Supreme Court proceedings concerning the property

The State submitted that the allegations of assault warranted investigation; the complainants did not appear to make submissions

1. Whether the FIR disclosed a basis to proceed against the petitioners for the alleged offences under the SC/ST (Prevention of Atrocities) Act and the IPC

2. Whether, in light of the history and circumstances of the property dispute, continuing the criminal proceedings would amount to an abuse of process warranting quashing under Section 482 CrPC

The petitions were brought under Section 482 of the Code of Criminal Procedure, which the Court invoked to prevent abuse of process and miscarriage of justice

The alleged offences arose under Sections 3(v) and 3(x) of the SC/ST (Prevention of Atrocities) Act, 1989, and Sections 506, 420, 504, 471, 323 and 468 read with Section 34 of the IPC

The Court referred to State of Haryana v. Ch. Bhajan Lal, reported as MANU/SC/0115/1992, and relied on the principle that the High Court may exercise its inherent jurisdiction where a criminal complaint is alleged to be motivated by personal vengeance and its continuation would constitute an abuse of process

The Court considered the complaint alongside the history of the parties’ property dispute and the earlier proceedings concerning title and revenue entries. It noted that the complainant had unsuccessfully pursued proceedings before the revenue authorities, the High Court and the Supreme Court, and characterised the underlying dispute as civil in nature

Although the State relied on allegations of assault, the Court concluded that the complaint had been lodged out of personal vengeance after the complainant’s unsuccessful litigation and that allowing the FIR to proceed would perpetuate vexatious proceedings. It therefore considered this a fit case for exercising Section 482 jurisdiction

allowed all three petitions and quashed the registration of Crime No. 1/2020 for the offences under the SC/ST (Prevention of Atrocities) Act and the IPC