$~42 * IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010280072025 + W.P.(CRL) 1528/2025 LALIT TYAGI .....Petitioner Through: Appearance not given. versus THE STATE OF GOVT. OF NCT OF DELHI AND ORS .....Respondents Through: Mr. Rahul Tyagi ASC CRL., Mr. Sangeet Sibou Adv., Mr. Priyansh Raj Singh Adv. SI Ekta Chauhan, ASI Yogindra Sharma, PS: Mayur Vihar. Mr. Himanshu Pathak, SPC along with Mr. Mohit Gupta, Advs. for R-2, 6 to 8. CORAM: HON’BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV O R D E R % 05.08.2026 1. The present petition seeks to challenge the order dated 14.02.2025 passed by the learned Addl. Sessions Judge, East District Karkardooma Courts (“Impugned Order”), whereby the revision petition filed by the petitioner against the order dated 21.11.2023 passed by the learned Metropolitan Magistrate, East District Karkardooma Courts, rejecting the petitioner’s application under Section 156(3) of the Code of Criminal Procedure, 1973 (“Cr.P.C”), seeking the registration of FIR, came to be dismissed. 2. The brief facts of the case, appear to be, that the complainant/petitioner started a business of sale and purchase of used cars with the husband of respondent no. 5/ late Ashok Kumar, under which he purchased a vehicle on 12.10.2021(“Said Vehicle”) and placed it in custody This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/08/2026 at 11:37:00 of Ashok Kumar for resale. On 14.12.2021, respondent no. 4 allgedely took the said vehicle without payment and the following day, Ashok Kumar committed suicide, leading to the registration of FIR No. 25/2022 at P.S. Mayur Vihar. During the investigation, the petitioner disclosed respondent no. 4’s unlawfully taking the said vehicle. Subsequently, respondent no. 5- widow of Ashok Kumar, allegedly pressured the petitioner to hand over the NOC of the said vehicle in exchange for exonerating him from the FIR. Despite submitting formal representations and complaints highlighting these alleged actions, no formal legal action was initiated on the petitioner's complaints. Thereafter, he filed application under Section 156(3) Cr.P.C. 3. The Supreme Court in the case of Inder Mohan Goswami v. State of Uttaranchal,1 held that the Courts must ensure that criminal prosecution is not used as an instrument of harassment or for seeking private vendetta or with an ulterior motive. The relevant para 46 is extractedas under:- “46. The court must ensure that criminal prosecution is not used as an instrument of harassment or for seeking private vendetta or with an ulterior motive to pressurise the accused. On analysis of the aforementioned cases, we are of the opinion that it is neither possible nor desirable to lay down an inflexible rule that would govern the exercise of inherent jurisdiction. Inherent jurisdiction of the High Courts under Section 482 CrPC though wide has to be exercised sparingly, carefully and with caution and only when it is justified by the tests specifically laid down in the statute itself and in the aforementioned cases. In view of the settled legal position, the impugned judgment cannot be sustained.” (Emphasis Supplied) 4. Para. 8 and 9 of the Impugned Order dated 14.02.2025 reads as under: “8. Firstly, it would be apt to deal with the aspect of limitation, the instant revision petition is filed after a delay of 181 days and the reason which has been given as sufficient cause is that the Ld. Counsel for revisionist applied certified copies but the same was not provided by the copying agency. This court is the considered opinion that the said ground cannot be considered to 1 (2007) 12 SCC 1 This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/08/2026 at 11:37:00 be sufficient cause for condonation of delay of 181 days. As per the slip/receipt of KKD Courts as enclosed by the Revisionist, the revisionist applied for certified copies on 01.12.2023 and the delivery date is mentioned 07.12.2023. Even if the submission in application for condonation of delay is believed to be true that certified copy of order has still not been received, the revisionist has filed the revision petition, wherein uncertified copy of the order has been placed. In any case, a digitally signed copy of the order is sufficient for preferring the revision petition. Therefore, the revision petition is barred by the Limitation as no sufficient caused of 181 days could be provided by the revisionist.” 9. Even otherwise, on merits also it appears to be the case of dispute related to sell and purchase of car and hence no cognizable offence fastening the criminal liability appears to be made out. The vague and unsubstantiated allegations against the respondents have been made by the revisionist on one hand says that Sh. J.C. Chauhan with the help of his criminal associate forcibly without paying the dues of the amount took away the car bearing NO. DL 12CM 2843 and on the other hand, in his “Representation in concern of FIR No. 25/2022, PS Mayur Vihar, on behalf of Lalit Tyagi”, which is placed at annexure A-2 of revision petition he mentions that he came to know that one person namely Chauhan had taken away the car bearing No. DL 12CM 2843 which was under the care of deceased Ashok Kumar, upon whom some dues of amount were pending but later on it was revealed that the said Chauhan has forcibly taken the said vehicle. It is not mentioned that how the Revisionist came to know that the J. C. Chauhan took the vehicle forcibly. The deceased Ashok Kumar committed suicide and his wife Dayawati is already a proposed Accused in his application u/s 156(3) Cr.P.C. From the perusal of the Application u/s 156(3) Cr.P.C., it is not clear that what role Respondent No. 3 i.e. Dayawati had in causing wrongful loss to the Revisionist and what are the facts upon which an FIR u/s 380/420/467/468 and 120-B IPC may be registered against her. On one hand Revisionist says that Respondent no. 2 i.e. J.C. Chauhan forcibly took vehicle from the possession of deceased Ashok Kumar and on the other hand makes the wife of the deceased a proposed accused. The allegation that Respondent No. 3 i.e., Dayawati threatened the revisionist to give NOC so that the FIR no. 25/2022 may be closed is also vague and unsubstantiated.” 5. Bearing in mind the findings rendered by the revisional Court, particularly those in paras. 8 and 9, this Court finds no merit in the present case. This matter herein relates to the sale and purchase of a car and no cognizable offence was made out. Therefore, no criminal liability can be This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/08/2026 at 11:37:00 fastened on the respondents merely on account of some private dispute. 6. In view of the aforesaid, finding no merit, the petition fails and is hereby dismissed. PURUSHAINDRA KUMAR KAURAV, J AUGUST 5, 2026/P/Ar This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 12/08/2026 at 11:37:00