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Supreme Court of India 2025-07-31 allowed

Urmila Devi & Ors vs Balram & Anr

Bench: 2 — B. V. Nagarathna, K.V. Viswanathan

In Brief

A testator executed a will in 1993 bequeathing his property to his daughters-in-law. His third son later sold his share to a third party (the complainant) via registered deed. The accused-appellants obtained a mutation order in their favour. The complainant filed a criminal complaint alleging forgery of the will to circumvent the sale deed. The Supreme Court held that the case was essentially a civil succession dispute disguised as criminal, with no prima facie ingredients of cheating or forgery present. The Court quashed the 20-year-old proceedings, finding they were instituted with mala fide intent after the complainant's civil remedies (objections to mutation order and counter-claim) had failed, thereby abusing the criminal justice system.

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Criminal Procedure Abuse of Process Section 482 CrPC Succession Property Rights Forgery Cheating Civil vs Criminal Disputes Inherent Jurisdiction

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