FIR arising from a commercial payment dispute quashed where allegations lacked requisite criminal-offence ingredients.

The petitioner, proprietor of Shri Ganpati Steels, challenged FIR No. 464/2025 dated 24 September 2025 registered at Police Station Civil Lines, Raipur, for offences under Sections 316 and 3(5) of the Bharatiya Nyaya Sanhita, 2023 (“BNS”), along with consequential criminal proceedings.

The FIR arose from commercial transactions concerning the sale and purchase of steel products and alleged outstanding payments.

The petitioner contended that the dispute was predominantly civil and commercial, and that the criminal case had been initiated to exert pressure for recovery of alleged dues.

The petitioner relied upon the High Court’s earlier order dated 13 August 2026 in WPCR No. 539 of 2025 and connected matters, which involved the same FIR and granted relief in similar circumstances.

Notice to respondent No. 2 was affixed at his residence after he refused to accept service; he did not appear before the Court.

The State opposed the petition but acknowledged that the matter was similar to the earlier decided cases.

Whether the FIR and consequential criminal proceedings arising from a commercial dispute concerning alleged outstanding payments disclosed the offences under Sections 316 and 3(5) of the BNS against the petitioner and were liable to be quashed?

Whether the petitioner was entitled to the same relief as granted in WPCR No. 539 of 2025 and connected matters by order dated 13 August 2026?

The Court exercised its jurisdiction under Article 226 of the Constitution of India, read with its inherent and extraordinary jurisdiction, to examine whether continuation of criminal proceedings arising from a commercial dispute constituted an abuse of the process of law.

The alleged offences were stated to arise under Sections 316 and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

The Court applied the principle that criminal proceedings may be quashed where the allegations, viewed in their factual and commercial context, do not warrant continuation of the prosecution and the matter is substantially civil in nature.

It further applied the principle of consistency and judicial parity by following its order dated 13 August 2026 in WPCR No. 539 of 2025 and analogous matters, which concerned the same FIR and substantially identical allegations.

The Court found that the FIR arose essentially from commercial dealings involving the sale and purchase of steel products and alleged non-payment of dues.

Although the petitioner asserted that the allegations did not satisfy the ingredients of the offences alleged, the Court principally relied on the fact that the present controversy was substantially identical to matters already decided in favour of similarly situated petitioners in the order dated 13 August 2026.

The State did not dispute the similarity between the cases.

In the absence of any distinguishing circumstance warranting a different view, the Court held that the petitioner was entitled to relief on the same terms as in the earlier decision.

FIR No. 464/2025 dated 24 September 2025 registered at Police Station Civil Lines, Raipur, for offences under Sections 316 and 3(5) of the BNS, together with all consequential criminal proceedings insofar as they related to the petitioner, was quashed.

The order was made subject to the same terms, conditions, and exceptions contained in the order dated 13 August 2026 in WPCR No. 539 of 2025 and connected matters.

No order as to costs was made.