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Supreme Court of India 2024-10-22 allowed

HDFC BANK LTD vs THE STATE OF BIHAR & ORS

Bench: 2 — B.R. Gavai, K.V. Viswanathan

In Brief

HDFC Bank sought to quash an FIR registering criminal charges against its officials and the bank for alleged violation of an income tax restraint order on a bank locker. The officials had inadvertently allowed a customer to operate the locker following a partial revocation order that they misinterpreted as applying to lockers (when it applied only to bank accounts). The Supreme Court held that the FIR did not disclose the essential ingredients of any of the alleged offences—including fraud, criminal breach of trust, or conspiracy—against the bank or its officials. The Court set aside the High Court's dismissal and quashed the FIR, finding the continued prosecution would cause undue hardship without any genuine legal foundation.

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Criminal Procedure Criminal Law Quashing of FIR Inherent Powers of Court Income Tax Investigation Bank Regulation Breach of Trust

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