The Supreme Court dismissed an appeal seeking quashing of criminal proceedings arising from a construction-related monetary dispute. The appellant argued that the matter was purely civil, relying on a “No-Dues Certificate” and accusing the complainant of misusing criminal law as pressure tactics after an injunction suit. However, the Court held that where allegations indicate inducement to undertake work without payment, a prima facie case of cheating and criminal intimidation may arise, even if civil remedies exist.
The Court emphasized that disputed documents like the No-Dues Certificate cannot be relied upon at the quashing stage. It reaffirmed that the High Court’s powers under Section 482 CrPC are to be used sparingly, and only when allegations are inherently improbable or legally barred, as laid down in Bhajan Lal. Since witness statements supported the complaint and the delay in proceedings was largely attributed to the appellant, continuation of trial was justified. The Court approved the High Court’s prior decision quashing only the Section 406 IPC charge, while allowing prosecution under Sections 420, 344, and 506 IPC to proceed
Rocky v. State of Telangana & Anr., 2025 INSC 1384 (Supreme Court, 4 Dec 2025)