Costs imposed for casual filing of photocopies instead of original settlement agreements in quashing petitions.

The petitioners filed a petition seeking to quash Charge-Sheet No. 339 of 2023, the order taking cognizance dated December 22, 2023, and the order framing charges dated February 11, 2026, in Criminal Case No. 22561 of 2023.

The proceedings arose from FIR No. 168 of 2022, involving offences under Sections 120B (criminal conspiracy) and 420 (cheating) of the Indian Penal Code.

The quashing was sought on the grounds of an amicable settlement between the parties.

However, the petitioners annexed only a colored photocopy of the original compromise deed dated December 9, 2025 (Annexure P/5), rather than the original document.

Upon query by the Court, the petitioners’ counsel sought to withdraw the petition to file it afresh with original documents.

1. Whether the quashing of criminal proceedings under Sections 120B and 420 of the IPC can be entertained when the compromise deed is submitted as a colored photocopy instead of an original document.

2. Whether the Court should impose costs for the "casual" filing of documents that results in the wastage of judicial time.

The Court emphasized the procedural requirement that original documents, specifically compromise/settlement agreements, must be filed to substantiate a prayer for quashing criminal proceedings based on a settlement.

Furthermore, the Court exercised its inherent power to impose compensatory costs on parties for filing petitions in a "most casual manner" and wasting the "precious time of the Court".

The substantive law involved Sections 120B and 420 of the Indian Penal Code, 1860.

The Court observed that the petitioners relied on a colored photocopy of a settlement deed to seek the quashing of serious criminal charges, including fraud and conspiracy.

When confronted with the absence of the original agreement, the petitioners’ counsel admitted the deficiency and requested withdrawal with liberty to refile.

The Court determined that such litigation conduct—filing essential settlement documents without the originals—constituted a casual approach to legal proceedings.

Consequently, while the Court allowed the withdrawal to serve the interests of justice, it held both the petitioners and the second respondent (the complainant) liable for costs due to the procedural lapse that hindered the Court's efficiency.

The Court imposed a total cost of ₹35,000 for the casual filing: ₹5,000 per petitioner (totaling ₹25,000) and ₹10,000 on Respondent No. 2.

These funds were directed to be transmitted to the Government Special School for Intellectual Retardation, Rajnandgaon.

The Court further ordered the return of certified copies to the petitioners upon the submission of attested true copies.