Criminal prosecution cannot be maintained for disputes of an exclusively civil nature arising from landlord-tenant relationships.

The Informant (Opposite Party No. 2), a tenant of Petitioner No. 1, alleged that he was requested to vacate two rooms for a family marriage under the assurance of restoration post-13.12.2010

He claimed the Petitioners subsequently refused him re-entry, withheld his belongings, and threatened him, leading to the registration of Kadamkuan P.S. Case No. 390/2010

Conversely, the Petitioners contended that the Informant was an evading defaulter who had voluntarily vacated the premises, as evidenced by a Title Eviction Suit (T.E.S. No. 41 of 2010) decreed ex-parte in favor of Petitioner No. 1

The Petitioners moved to quash the order dated 24.09.2019 passed by the Additional Sessions Judge, IX, Patna, which had upheld the dismissal of their discharge application by the JMFC, Patna

1. Whether the criminal proceedings against the Petitioners were an attempt to give a civil dispute the color of a criminal offense to exert undue pressure

2. Whether the impugned revisional order and the underlying criminal proceedings serve the ends of justice given the prior civil adjudication of the dispute

The Court primarily relied on the legal principle established by the Supreme Court of India in M/s Indian Oil Corporation v. M/s NEPC India Ltd., & Ors. (AIR 2006 SC 2780), which mandates that any effort to settle purely civil disputes and claims through the pressure of criminal prosecution should be deprecated and discouraged

The Court observed that the dispute was essentially a landlord-tenant conflict of a civil nature, noting that a Title Eviction Suit had already been decreed in favor of the Petitioners, where the civil court recorded that the Informant had vacated the premises

Applying the doctrine from M/s Indian Oil Corporation, the Court reasoned that the criminal case was a deliberate attempt by the Informant to entangle the Petitioners in prosecution to force a settlement

Since the core of the grievance—possession and tenancy—was already adjudicated or subject to civil remedies, the continuation of criminal proceedings for alleged harassment regarding the same property amounted to an abuse of process

The Court granted liberty to Opposite Party No. 2 to file a review application should any facts previously unknown to the Court come to light