“The valuable time of the police is consumed in investigating disputes that seem more suited for civil resolution:” Supreme Court

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While hearing the Deepak Kumar Shrivas & Anr. vs. State of Chhattisgarh & Ors. case on February 19, 2024, the Supreme Court (SC) of India expressed concern over the time wasted by the police in investigating cases that ought to be suited for civil resolution. The judgment reads “It becomes evident that the police finds itself entangled in the irrelevant and trivial details of…unethical private issues, diverting the resources away from the pursuit of more consequential matters. The valuable time of the police is consumed in investigating disputes that seem more suited for civil resolution. This underscores the need for a judicious allocation of law enforcement resources, emphasizing the importance of channeling their efforts towards matters of greater societal consequence.” The SC bench consisting of Justice Vikram Nath and Justice Satish Chandra Sharma also held that the police should exercise heightened caution when drawn into disputes about unethical transactions between private parties. It further added, “The need for vigilance on the part of the police is paramount, and a discerning eye should be cast upon cases where unscrupulous conduct appears to eclipse the pursuit of justice. This case exemplifies the need for a circumspect approach in discerning the genuine from the spurious and thus ensuring that the resources of the state are utilized for matters of true societal import.”

In this case, the challenge is to the correctness of the judgment passed by the Division bench of the Chhattisgarh High Court (HC) dismissing the writ petition of the appellant for quashing criminal proceedings arising out of FIR. Herein, the appellant made a complaint on April 06, 2021, to the Collector, District Janjgir-Champa (Chhattisgarh) alleging that Rajkumari Maravi (Respondent No. 6) had allured the appellant that she would secure a job for his brother as she had good contacts with higher officers and demanded substantial amount for doing this favor. The appellant was allured and paid Rs. 80,000/- in cash at the first instance. Later on, an additional demand was made and, according to the complaint made by the appellant, he deposited Rs. 20,000/- and odd in different bank accounts, details of which were provided by Rajkumari Maravi. When nothing happened and no job was provided to his brother, he approached the Rajkumari Maravi to return the money paid by him upon which she threatened him with false implication, and later on she stopped responding to his calls and started avoiding him. In this context, the appellant filed a petition under Article 226 of the Constitution of India before the HC to quash the FIR and the proceedings arising therefrom. The said petition was dismissed by the impugned order giving rise to the filing of the present appeal.

While pronouncing the judgment, the SC bench noted “Beyond the immediate contours of the case, a broader question emerges regarding the balancing of interests that ought to be done between addressing unscrupulous private grievances and safeguarding public interests.” After hearing the contentions, the SC opined that “such criminal  prosecution  should  not be allowed to continue where the object to lodge the FIR is not for criminal prosecution and for punishing the offender for the offence committed but for recovery of money under coercion and pressure…” Therefore, the bench set aside the impugned order of the HC and quashed the entire proceedings arising out of the FIR.