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Supreme Court of India 2024-04-05 allowed

THE STATE OF MADHYA PRADESH vs SHILPA JAIN & ORS

Bench: 2 — Vikram Nath, Satish Chandra Sharma

In Brief

The State of Madhya Pradesh challenged a High Court order quashing a criminal FIR alleging fraudulent sale of government nazul land through forged documents. The respondents had purchased the property in private sale transactions. The Supreme Court held that while the underlying dispute originated from civil proceedings concerning property possession, the criminal allegations—involving forgery, fraud, and connivance with officials in selling state property—constitute a genuine criminal matter that should not be quashed. The Court rejected arguments that revenue proceedings established private title, holding that only civil courts determine property ownership. The FIR was reinstated for investigation on its merits.

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Criminal Procedure Quashing of FIR Fraud and Forgery Government Property Revenue Law Abuse of Process Title to Property

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