C.S. Prasad vs C. Satyakumar and Others; 2026 INSC 39 - S.482 CrPC - Quashing - Civil Suit - Delay

Code of Criminal Procedure 1973 - Section 482 - Civil Nature - Civil adjudication cannot always be treated as determinative of criminal culpability at the stage of quashment- Civil liability and criminal liability may arise from the same set of facts and that the pendency or conclusion of civil proceedings does not bar prosecution where the ingredients of a criminal offence are disclosed- Adjudication of forgery, cheating or use of forged documents in relation to a settlement deed will always carry a civil element. To permit quashing on the sole ground of a civil suit would encourage unscrupulous litigants to defeat criminal prosecution by instituting civil proceedings. (Para 26-28)

Code of Criminal Procedure 1973 - Section 482 -Delay - Delay in filing a complaint, by itself, is never a ground for quashing criminal proceedings at the threshold. Whether the delay stands satisfactorily explained or whether it impacts the credibility of the prosecution, is a matter of appreciation of evidence before the Trial Court and not for summary determination by the High Court under Section 482 of the Cr.PC

Code of Criminal Procedure 1973 - Section 482 - Scope -Even though the powers under Section 482 of the Cr.PC are very wide, its conferment requires the High Courts to be more cautious and diligent. While examining any FIR, the High Court exercising its power under this provision cannot go embarking upon the genuineness of the allegations made. The High Court must only consider whether there exists any sufficient material to proceed against the accused or not and must not be concerned with the reliability, sufficiency, or acceptability of the evidence. (Para 24) High Court in its jurisdiction under Section 482 is bound to take the allegations (made in complaint) on its face value. Whether these allegations can ultimately be proved is a matter strictly within the province of the Trial Court (Para 25)-when a factual foundation for prosecution exists, criminal law cannot be short-circuited by invoking inherent jurisdiction under Section 482 of the Cr.PC. Where allegations require adjudication on evidence, the proper course is to permit the trial to proceed in accordance with law.  (Para 31)

Summary: The Supreme Court set aside the Madras High Court’s order quashing criminal proceedings against accused.