Habitual Filing of False Complaints to Pressure Rivals in Property Dispute Can Invite Action Under Punjab Police Act: P&H High Court Refuses to Quash Proceedings
Case Name: Radha Rani v. State of Punjab and Others
Date of Judgment: 29 May 2026
Citation: CRM-M-36508-2017
Bench: Justice H.S. Grewal
Held: The Punjab & Haryana High Court held that where repeated police inquiries consistently find complaints to be false and motivated, and the material on record discloses a pattern of using criminal allegations to pressurize private parties in an ongoing property dispute, initiation of proceedings under Section 66 of the Punjab Police Act, 2007 cannot be termed arbitrary or illegal. The Court refused to exercise its inherent jurisdiction to quash the proceedings.
Summary: The petitioner approached the High Court under Section 482 Cr.P.C. seeking quashing of Kalandra No. 8665-A dated 22 July 2017 initiated against her under Section 66 of the Punjab Police Act, 2007 and all consequential proceedings arising therefrom.
The dispute stemmed from a long-running family property conflict between the petitioner and her brothers. According to the prosecution, the petitioner claimed a share in family land and repeatedly lodged criminal complaints against her brothers and other family members with the object of exerting pressure in the ongoing civil dispute. The allegations against her were that she habitually lodged false complaints and fabricated incidents in an attempt to strengthen her claim over the property.
The petitioner contended that she had merely exercised her legal right to approach law-enforcement authorities and that the proceedings under Section 66 of the Punjab Police Act amounted to harassment. It was argued that the complaints were genuine and that initiation of proceedings against her for approaching the police was unjustified.
The State and the private respondents opposed the petition by asserting that the petitioner had repeatedly misused the criminal justice system to settle scores arising out of the property dispute. They pointed out that several complaints lodged by her had already been investigated and found to be false. According to the respondents, the proceedings under Section 66 were initiated only after detailed inquiries established a pattern of abuse of the complaint mechanism.
The Court examined the material collected during the inquiries. It noted that one of the complaints made by the petitioner concerning an alleged incident dated 28 April 2017 was thoroughly investigated and culminated in DDR No. 27 dated 12 May 2017, wherein the authorities concluded that no such incident had occurred and that no injuries had been caused in the manner alleged.
The Court further referred to a detailed inquiry conducted by the Deputy Superintendent of Police, Abohar, who submitted a report concluding that the petitioner was habitually filing false complaints and was even alleged to have inflicted simple injuries upon herself in order to falsely implicate the respondents. On the basis of these findings, initiation of proceedings under Section 66 of the Punjab Police Act was recommended.
Significantly, the Court observed that the conduct complained of did not stop after initiation of the proceedings. The record revealed that the petitioner continued filing multiple complaints against the respondents over the years. Various inquiries conducted by police authorities repeatedly concluded that the controversy essentially related to distribution and ownership of family land and did not disclose criminal offences warranting police action.
The Court also noted that extensive civil litigation had already taken place between the parties concerning the same property. Several suits and proceedings challenging ownership rights had been instituted, demonstrating that the core dispute was civil in nature. The High Court found force in the respondents’ contention that criminal proceedings were being invoked as a pressure tactic in aid of the civil dispute.
While examining the legality of the Kalandra proceedings, the Court emphasized that the authorities were entitled to consider the overall conduct of a complainant and the surrounding circumstances. Where repeated complaints are found to be false after inquiry, initiation of proceedings under Section 66 of the Punjab Police Act cannot be faulted merely because the complainant asserts that her allegations were genuine.
The Court ultimately found that the record disclosed a continuing pattern of filing complaints that were repeatedly found to be without merit. Such conduct justified the action taken by the police authorities and did not warrant interference under the Court’s inherent powers.
Decision: The Punjab & Haryana High Court dismissed the petition and upheld Kalandra No. 8665-A dated 22 July 2017 initiated under Section 66 of the Punjab Police Act, 2007. The Court held that the police authorities were justified in considering the petitioner’s repeated filing of complaints found to be false and that no illegality or arbitrariness was made out warranting quashing of the proceedings.