1. State of Haryana v. Bhajan Lal
Citation: 1992 Supp (1) SCC 335
Facts:
A corruption FIR was registered against the former CM. Bhajan Lal argued that the allegations were politically motivated and did not disclose any offence.
Principle:
The Supreme Court laid down the famous 7 categories where FIR/Criminal proceedings can be quashed.
Significance:
Most authoritative judgment on quashing FIR; every court relies on it.
Introduced “abuse of process of law” standard.
2. R.P. Kapur v. State of Punjab
Citation: AIR 1960 SC 866
Facts:
Accused sought quashing of criminal proceedings arguing no legal evidence existed.
Principle:
First classic three grounds for quashing were laid down:
- Allegations do not constitute any offence.
- There is a legal bar to proceedings.
- No evidence to support allegations.
Significance:
Foundation for Bhajan Lal principles.
Still cited for “no offence disclosed” category.
3. Zandu Pharmaceutical Works Ltd. v. Mohd. Sharaful Haque
Citation: (2005) 1 SCC 122
Facts:
Disputes were purely commercial/civil in nature but criminal case was filed.
Principle:
Criminal law cannot be used as a weapon in purely civil disputes.
Significance:
Often used in business, property, partnership disputes where FIR is filed to pressurize.
4. Pepsi Foods Ltd. v. Special Judicial Magistrate
Citation: (1998) 5 SCC 749
Facts:
Company executives were wrongly prosecuted without proper application of mind.
Principle:
Summoning in criminal cases is serious; magistrate must apply mind.
Significance:
Used when FIR/complaint is filed against directors/companies without role or evidence.
5. State of Karnataka v. L. Muniswamy
Citation: (1977) 2 SCC 699
Facts:
Accused argued that continuing criminal proceedings serves no purpose.
Principle:
Court may quash criminal proceedings if the case is manifestly unjust, futile, or oppressive.
Significance:
Establishes High Court’s inherent power to prevent injustice.
6. Parbatbhai Aahir v. State of Gujarat
Citation: (2017) 9 SCC 641
Facts:
Settlement occurred between parties in a non-compoundable offence.
Principle:
Laid down updated principles for quashing on compromise.
Significance:
Very important in matrimonial, commercial, property disputes.
7. Gian Singh v. State of Punjab
Citation: (2012) 10 SCC 303
Facts:
Accused sought quashing of non-compoundable offences after compromise.
Principle:
High Courts can quash FIR even in non-compoundable offences if the dispute is private and parties settled.
Significance:
Key case for compromise quashing.
Clarified difference between compounding & quashing.
8. Narinder Singh v. State of Punjab
Citation: (2014) 6 SCC 466
Facts:
Parties compromised in a case involving Section 307 IPC.
Principle:
For serious offences, court must verify injury nature, weapon, intention before quashing.
Significance:
Frequently used in attempt-to-murder compromise quashing petitions.
9. Priti Gupta v. State of Jharkhand
Citation: (2010) 7 SCC 667
Facts:
Family members were falsely implicated in Section 498A IPC.
Principle:
Courts must be cautious in 498A cases; relatives cannot be roped in casually.
Significance:
Used widely in 498A quashing for distant relatives / false implication.
10. Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra
Citation: (2021) 6 SCC 116
Facts:
Issue was whether courts can stay investigation easily.
Principle:
Courts should not pass routine stay orders on FIR investigation.
Significance:
Clarified limits of quashing at investigation stage.
Strong reminder that interference must be rare.
11. Joseph Salvaraj A. v. State of Gujarat
Citation: (2011) 7 SCC 59
Facts:
Delay in FIR and no evidence against accused.
Principle:
Weak/absent evidence grounds can be considered during quashing.
Significance:
Helpful where FIR is delayed, vague, or malicious.
12. Vesa Holdings Pvt. Ltd. v. State of Kerala
Citation: (2015) 8 SCC 293
Facts:
Commercial dispute converted into cheating FIR.
Principle:
Cheating FIR cannot survive if there was no dishonest intention at inception.
Significance:
Used for cheating (420 IPC) cases arising from business disputes.
Add a Comment