Human Rights Commission lacks jurisdiction to adjudicate property disputes or direct FIR registration in civil matters.

The Petitioner challenged an order dated May 31, 2023, passed by the Maharashtra State Human Rights Commission ("the Commission").

The dispute originated from a real estate transaction involving Survey No. 269 between the Petitioner and Respondent No. 3.

Respondent No. 3 alleged that the Petitioner used forged documents to gain possession and claimed that the police, in collusion with the Petitioner, refused to register his FIR while filing a "false" charge sheet against him in Crime No. 54 of 2020.

Respondent No. 3's previous attempt to quash said FIR was dismissed by the High Court.

The Commission, however, directed the Commissioner of Police and Municipal Commissioner to initiate steps under Section 18(e) of the Protection of Human Rights Act, 1993 ("the Act"), effectively directing the registration of Respondent No. 3's FIR and reconsideration of municipal approvals.

Whether the State Human Rights Commission has the jurisdiction to entertain complaints arising out of purely civil property disputes and sub-judice criminal matters.

Whether the failure of police to register a cross-complaint in a commercial property dispute constitutes a "human rights violation" under Section 2(1)(d) of the Act.

The court primarily applied Section 2(1)(d) of the Protection of Human Rights Act, 1993, which defines human rights as those relating to life, liberty, equality, and dignity enforceable by courts.

It relied on Regulations 8(d), 8(g), and 8(h) of the Maharashtra State Human Rights Commission (Procedure) Regulations, 2011, which mandate the dismissal in limine of complaints relating to civil disputes, matters lacking specific human rights violations, or sub-judice cases.

The court distinguished St. Anthony High School v. Uma Umakant Chodankar regarding the prematurity of challenges to Commission recommendations

The court distinguished Lalita Kumari v. Govt. of U.P. regarding the mandatory registration of FIRs.

The Court reasoned that the Commission’s jurisdiction is strictly circumscribed by the statutory definition of "human rights" and the 2011 Regulations.

In this case, the dispute was "quintessentially civil in nature," involving property titles and contractual obligations between real estate developers.

The Court found that the Commission bypassed Regulation 8(d) and 8(h) despite acknowledging that civil and criminal litigations were already pending in competent courts.

Furthermore, the Court observed that the complaint did not disclose any infringement of life or dignity; rather, it was an attempt to use the Commission as a parallel forum to redress grievances for which adequate remedies exist under the Code of Criminal Procedure.

The Court held that the Commission misdirected itself by applying the Lalita Kumari principle to a forum intended specifically for human rights protection, not general police oversight in commercial disputes.

It held that the complaint was "misconceived" as it did not meet the threshold of a prima facie human rights violation and fell within the prohibited categories of civil and sub-judice disputes under Regulation 8.

The parties were granted liberty to pursue appropriate legal remedies before civil and criminal courts.