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Supreme Court of India 2025-07-31 allowed

S. N. Vijayalakshmi & Ors vs State of Karnataka & Anr

Bench: 2 — Sudhanshu Dhulia, Ahsanuddin Amanullah

In Brief

The Supreme Court quashed an FIR lodged over a property dispute involving an Agreement to Sell. The appellants, as owners of the property, had agreed to sell land to the complainant but later refused to transfer it after obtaining higher offers. The Court held that criminal breach of trust (Section 406 IPC) cannot apply to owners; it requires entrustment by another. Cheating (Section 420 IPC) was also not made out, as possession was never handed over to the complainant. While civil and criminal cases can coexist, absent clear criminality, allowing both constitutes abuse of process. The Court quashed the FIR and directed that no third-party rights be created pending a related BDA petition.

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Criminal Breach of Trust Cheating and Fraud Property Disputes Code of Criminal Procedure Abuse of Process Private Complaint Procedure Civil and Criminal Proceedings Quashing of FIR

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