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Supreme Court of India 2019-02-15 allowed

PROF. R.K. VIJAYASARATHY vs SUDHA SEETHARAM

Bench: 2 — Dhananjaya Y Chandrachud, Hemant Gupta

In Brief

A son transferred Rs 20 lakhs to the first respondent's account in 2010 following his wife's car accident abroad. When marital relations broke down, the son sued for recovery of the money. The first respondent then filed a criminal complaint against the son's parents (appellants) alleging criminal breach of trust, cheating, and related offences. The Supreme Court allowed the appeal, holding that the complaint lacked the essential ingredients of criminal offences—particularly the requisite entrustment for breach of trust and dishonest inducement for cheating. The money belonged to the son and was held in trust for him; no criminal ingredients were established. The complaint, filed six years after the transaction and three years after the civil suit, was an abuse of process attempting to cloak a civil dispute in criminal form. The criminal proceedings were quashed.

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Criminal Procedure Criminal Breach of Trust Cheating Quashing of Proceedings Abuse of Process Civil and Criminal Law Distinction

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