Anukul Singh v. State of Uttar Pradesh 2025 INSC 1153 - S.482 CrPC - Civil Nature
Code of Criminal Procedure 1973 - Section 482 : Bharatiya Nagarik Suraksha Sanhita 2023 - Section 528 - While the jurisdiction under Section 482 Cr.P.C is extraordinary and must be exercised sparingly, it is the duty of the High Court to intervene where continuation of criminal proceedings would amount to an abuse of process of law, or where the dispute is purely of a civil nature and criminal colour has been artificially given to it. Conversely, where disputed questions of fact arise requiring adjudication, the matter must ordinarily proceed to trial. (Para 11.5) Criminal law cannot be used as a tool to settle scores in commercial or contractual matters, and that such misuse amounts to abuse of process. (Para 17) criminal complaints in respect of property disputes of civil nature, filed solely to harass the accused or to exert pressure in civil litigation, constitute an abuse of process. (Para 18) The dispute – concerning repayment of loan money and the alleged coercion in execution of documents – is purely civil in character. The institution of multiple FIRs in quick succession, particularly after the accused had already initiated lawful proceedings, reinforces the inference of mala fides. (Para 20)
Case Info
The case is
Case Name and Neutral Citation
- Case Name: Anukul Singh v. State of Uttar Pradesh and Another
- Neutral Citation: 2025 INSC 1153
Coram
- Judges: B.V. Nagarathna and R. Mahadevan
Judgment Date
- Date: September 24, 2025
Caselaws and Citations Referred
- State of Haryana v. Bhajan LalCitation: 1992 Supp (1) SCC 335 : 1992 SCC (Cri) 426
- Suryalakshmi Cotton Mills Ltd. v. Rajvir Industries Ltd.Citation: (2008) 13 SCC 678
- Anand Kumar Mohatta v. State (NCT of Delhi)Citation: (2019) 11 SCC 706
- Mukesh and others v. State of UP and othersCitation: SLP (Crl) No. 12354 of 2024 decided on 29.11.2024
- Md. Allauddin Khan v. State of Bihar and othersCitation: (2019) 6 SCC 107; Criminal Appeal No. 675 of 2019
- Rajiv Thapar v. Madal Lal KapoorCitation: (2013) 3 SCC 330
- HMT Watches v. AbidaCitation: (2015) 11 SCC 776
- Rathish Babu Unnikrishnan v. the State (Govt. of NCT of Delhi) and othersCitation: MANU/SC/0542/2022
- CBI v. Aryan SinghCitation: (2023) 18 SCC 399
- Indian Oil Corporation v. M/s. NEPC India Ltd.Citation: (2006) 6 SCC 738
- Inder Mohan Goswami and another v. State of Uttaranchal and othersCitation: AIR 2008 SC 251
- Ganga Dhar Kalita v. State of AssamCitation: (2015) 9 SCC 647
- Shailesh Kumar Singh @ Shailesh R. Singh v. State of Uttar Pradesh and othersCitation: Criminal Appeal No. 2963/2025 decided on 14.07.2025 : 2025 INSC 869
- Delhi Race Club (1940) Limited vs. State of Uttar PradeshCitation: (2024) 10 SCC 690
Statutes / Laws Referred
- Code of Criminal Procedure, 1973 (Cr.P.C.)
- Section 482
- Indian Penal Code, 1860 (IPC)
- Sections 420, 467, 468, 406, 506
- Negotiable Instruments Act, 1881 (N.I. Act)
- Section 138
- Constitution of India
- Article 226 (mentioned in context of writ petition)
Suggested Readings:
Yash Mittal