Vicarious criminal liability cannot be Peak-fastened upon departmental officers for statutory compensation errors falling under the Collector's exclusive jurisdiction.

The petitioner, an Assistant Engineer in the Water Resources Department, sought the quashing of FIR No. 536/2021 registered at PS Chanderi for offences under Sections 420, 467, 468, and 471 of the IPC.

The case involved fraudulent withdrawal of ₹20,00,000/- compensation for land acquired for the Lower Orr Dam Project.

It was alleged that an impostor opened a bank account using modified Aadhaar details to receive funds meant for the original landowner, Mahesh.

The prosecution alleged the petitioner was responsible for forwarding the list of beneficiaries containing the fraudulent bank details.

The petitioner contended he assumed charge as Project Administrator on July 30, 2021, whereas the compensation award was passed in 2018 and the list of beneficiaries was forwarded on February 21, 2019.

1. Whether the petitioner can be held criminally liable for discrepancies in the disbursement of compensation when the statutory responsibility for such disbursement rests with the Collector and Land Acquisition Officer.

2. Whether the continuation of criminal proceedings against the petitioner amounts to an abuse of the process of law given the timeline of his appointment relative to the alleged fraud.

The Court primarily applied the statutory framework of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, specifically Sections 3, 23, 26, 27, 28, and 77, which mandate that the Collector is the sole authority responsible for determining and making payment of compensation to "persons interested".

The Court further applied the principle governing the quashing of FIRs under Article 226 of the Constitution of India, establishing that proceedings may be quashed where allegations, even if taken at face value, do not disclose essential ingredients of the offence or where the process is an abuse of law.

The Court observed that under the Act of 2013, the responsibility for verifying the identity of beneficiaries and transferring funds lies exclusively with the Revenue Authority (Collector/Land Acquisition Officer), not the Water Resources Department.

Chronologically, the court found that the compensation award was approved on July 28, 2018, and the list containing the fraudulent details was forwarded on February 21, 2019.

The petitioner only assumed charge as Project Administrator on July 30, 2021 (or February 1, 2021, per conflicting records), both dates being significantly after the alleged fraudulent list was prepared and processed.

The State failed to provide documentary evidence to prove the petitioner held the post during the relevant period of 2018-2019.

Consequently, the Court determined there was no material evidence linking the petitioner to forgery or wrongful gain.

The Court allowed the writ petition and quashed FIR No. 536/2021 and all consequential proceedings insofar as they related to the petitioner to prevent the abuse of the process of law.

No order as to costs was made.