Criminal law cannot be invoked to resolve purely civil disputes or supplementary charges lacking fresh evidence.

The appellant is the daughter of late Onkar Singh and Mohinder Kaur. Following her father’s death, the appellant acquired rights over certain properties via succession.

A de-facto complainant (Respondent No. 2), alleging possession of certain lands, filed FIR No. 588/2018 alleging that the appellant’s mother executed forged General Power of Attorneys (GPAs) to transfer land to third parties, including portions belonging to the State of Uttar Pradesh.

Although the appellant was named in the initial information statement, she was not arrayed as an accused until a supplementary FIR/report was filed, despite no new evidence being unearthed.

The High Court declined to quash the FIR, holding that criminal elements existed regarding the forged GPAs despite the underlying civil nature of the land dispute.

1. Whether the filing of a supplementary FIR/report arraying the appellant as an accused was sustainable in the absence of new evidence.

2. Whether the allegations involving the execution of GPAs and conveyance of property in excess of title constitute a criminal offense or a purely civil dispute.

The court relied on the precedent in Mariam Fasihuddin Anr. v. State by Adugodi Police Station Anr. (2024) 11 SCC 733, which discourages the submission of supplementary reports in the absence of fresh evidence.

It further applied the principle that criminal law cannot be weaponized to resolve or gain leverage in purely civil disputes.

The Court observed that the appellant was only added as an accused through a supplementary process without any new material being unearthed after the first FIR.

Regarding the merits, the Court found the allegation of "fake" GPAs illogical because the prosecution admitted the GPAs were executed by the actual title holders (the mother and daughter).

Furthermore, the Court reasoned that if a vendor conveys more land than they legally own or refers to a non-existent jamabandi in a sale deed, the grievance lies with the purchasers, not a third-party complainant alleging possession.

The Court concluded that the dispute was essentially civil in nature, as evidenced by a pending civil suit initiated by the respondent, and lacked the necessary elements of criminality.

The Court allowed the appeal and quashed FIR No. 588 dated 02.06.2018 (Annexure P10) specifically insofar as it concerned the appellant.

The Court emphasized that criminal law must not be used to further a cause in a purely civil dispute.