FIR Quashed in Land Deal Dispute: Punjab & Haryana High Court Holds Criminal Case Filed to Escape Civil Liability
Case Name: Parveen Nain and Others v. State of Haryana and Another
Date of Judgment: 23 February 2026
Citation: CRM-M-48399-2022
Bench: Hon’ble Justice H.S. Grewal
Held: The Punjab & Haryana High Court held that criminal proceedings cannot be used to settle civil disputes arising out of contractual transactions. Where allegations in the FIR do not disclose prima facie offences of cheating or forgery and the dispute essentially relates to an agreement to sell, continuation of criminal proceedings amounts to abuse of the process of law. Accordingly, the FIR and all consequential proceedings were quashed.
Summary: The petitioners approached the High Court under Section 482 CrPC seeking quashing of FIR No. 0028 dated 13.01.2022 registered at Police Station City Sonipat under Sections 120-B, 420, 467, 468 and 471 IPC, along with all consequential proceedings.
The complainant alleged that he had entered into an agreement to sell land measuring approximately 56 kanals 3 marlas to the accused at the rate of ₹1.25 crore per acre. According to him, the accused fraudulently altered one of the agreements and mentioned the sale consideration as ₹25 lakh per acre instead of ₹1.25 crore per acre, thereby committing forgery and cheating.
It was further alleged that the accused used this allegedly forged agreement to file a civil suit for specific performance. The complainant claimed that the accused threatened him and demanded ₹6 crore.
The petitioners contended that the dispute was purely civil in nature arising out of an agreement to sell. They submitted that civil suits regarding the transaction had already been filed and that the criminal case was initiated only to pressurise them.
The State and the complainant argued that criminal proceedings could continue even if civil remedies existed and relied upon Supreme Court precedent to argue that pendency of civil proceedings does not justify quashing criminal prosecution where prima facie offences are made out.
Upon examining the agreement to sell, the High Court found that it was a registered document and contained no visible alterations, overwriting, or cutting regarding the sale consideration. The Court further noted a significant inconsistency in the complainant’s case: although he claimed that the agreed rate in 2019 was ₹1.25 crore per acre, he himself sold the same land in 2021 for only ₹35 lakh per acre.
The Court also observed that the petitioners had appeared before the Sub-Registrar on the date fixed for execution of the sale deed and had marked their presence through affidavits and photographs, indicating their readiness to perform the contract.
These circumstances indicated that the complainant, rather than the petitioners, had failed to honour the agreement and had resorted to criminal proceedings to avoid civil liability.
Relying on the principles laid down in State of Haryana v. Bhajan Lal and Indian Oil Corporation v. NEPC India Ltd., the Court reiterated that criminal law should not be used as a tool for settling civil disputes. The Court also referred to recent Supreme Court guidance discouraging the conversion of contractual disputes into criminal cases.
The Court concluded that the allegations in the FIR did not disclose any prima facie offence of cheating or forgery and that the case was essentially a civil dispute given a criminal colour.
Decision: The High Court allowed the petition and quashed FIR No. 0028 dated 13.01.2022 registered under Sections 120-B, 420, 467, 468 and 471 IPC at Police Station City Sonipat, District Sonipat, along with the challan and all consequential proceedings against the petitioners.