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Supreme Court of India 2019-04-15 allowed

Md. Allauddin Khan vs State of Bihar & Ors

Bench: 2 — Abhay Manohar Sapre

In Brief

A complainant alleged criminal assault and theft against two persons in connection with a property dispute. A Judicial Magistrate took cognizance and found a prima facie case existed. The High Court quashed the complaint, treating the matter as purely civil because an eviction and title suit were pending. The Supreme Court held the High Court erred: mere pendency of civil suits does not bar criminal prosecution if the complaint allegations prima facie constitute the charged offences. The Court found the High Court wrongly assessed evidence contradictions—a trial court function, not permissible at the cognizance stage under Section 482 CrPC. The appeal was allowed and the case restored for trial."

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Criminal Procedure Prima Facie Case Quashing of Complaint Cognizance Civil Disputes

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