CRM-M-14507- IN THE HIGH COURT OF PUNJAB AND HARYANA Devendra Kamal Srivstav and Others State of Haryana and Another CORAM : HON'BLE MS Present: Mr. Akshay Jindal, Sr. Advocate with Mrs. Garima Jindal, Advocate and Mr. Vrishank Suri, Advocate for the petitioners. Mr. Sushil Bhardwaj, Addl. A.G. Haryana. Mr. Narender Hooda, Sr. Advocate Mr. Roopansh Purohit and Mr. Karanvir Hooda, Advocates for respondent no.2. MANDEEP PANNU J. 1. he present petition under Suraksha Sanhita has been filed for quashing of FIR No. 15 dated 11.02.2026 registered at Police Station Mohammadpur Ahir, District Nuh, Haryana under Sections 420, 467, 468, 471 of the IPC ( all consequential proceedings arising therefrom. 2. Briefly, the facts necessary for adjudication of the present petition are that the dispute between the parties pertains to a property in respect of which competing claims have been raised regarding ownership, possession, and validity of documents including of the complainant that the said lease deed is forged and fabricated and has been used to defeat his rights in the property. The petitioners, on the other hand, assert their lawful rights flowin -2026 (O&M) IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH -.- CRM Date of Decision : Devendra Kamal Srivstav and Others VERSUS State of Haryana and Another HON'BLE MS. JUSTICE MANDEEP PANNU Mr. Akshay Jindal, Sr. Advocate with Mrs. Garima Jindal, Advocate and Mr. Vrishank Suri, Advocate for the petitioners. Mr. Sushil Bhardwaj, Addl. A.G. Haryana. Mr. Narender Hooda, Sr. Advocate (through Video Conferencing) Mr. Roopansh Purohit and Mr. Karanvir Hooda, Advocates for respondent no.2. -.- MANDEEP PANNU J. (Oral) he present petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita has been filed for quashing of FIR No. 15 dated 11.02.2026 registered at Police Station Mohammadpur Ahir, District Nuh, Haryana under Sections 420, 467, 468, 471 of the IPC (318(4), 338, 336(3), 340(2) all consequential proceedings arising therefrom. Briefly, the facts necessary for adjudication of the present petition are that the dispute between the parties pertains to a property in respect of which competing claims have been raised regarding ownership, possession, and validity of documents including sale deeds and a lease deed dated 23.08.2022. It is the case of the complainant that the said lease deed is forged and fabricated and has been used to defeat his rights in the property. The petitioners, on the other hand, assert their lawful rights flowing from the documents executed in their favour. It is not in -1- IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CRM-M-14507-2026 (O&M) Date of Decision : 23.03.2026 ....Petitioners ....Respondents MANDEEP PANNU Mr. Akshay Jindal, Sr. Advocate with Mr. Vrishank Suri, Advocate for the petitioners. Mr. Sushil Bhardwaj, Addl. A.G. Haryana. (through Video Conferencing) with Mr. Roopansh Purohit and Mr. Karanvir Hooda, Advocates Section 528 of the Bharatiya Nagarik Suraksha Sanhita has been filed for quashing of FIR No. 15 dated 11.02.2026 registered at Police Station Mohammadpur Ahir, District Nuh, Haryana under 318(4), 338, 336(3), 340(2) of BNS) and all consequential proceedings arising therefrom. Briefly, the facts necessary for adjudication of the present petition are that the dispute between the parties pertains to a property in respect of which competing claims have been raised regarding ownership, possession, and validity sale deeds and a lease deed dated 23.08.2022. It is the case of the complainant that the said lease deed is forged and fabricated and has been used to defeat his rights in the property. The petitioners, on the other hand, assert g from the documents executed in their favour. It is not in with Section 528 of the Bharatiya Nagarik Suraksha Sanhita has been filed for quashing of FIR No. 15 dated 11.02.2026 registered at Police Station Mohammadpur Ahir, District Nuh, Haryana under ) and Briefly, the facts necessary for adjudication of the present petition are that the dispute between the parties pertains to a property in respect of which competing claims have been raised regarding ownership, possession, and validity sale deeds and a lease deed dated 23.08.2022. It is the case of the complainant that the said lease deed is forged and fabricated and has been used to defeat his rights in the property. The petitioners, on the other hand, assert g from the documents executed in their favour. It is not in TRIPTI SAINI 2026.03.24 09:38 I attest to the accuracy and integrity of this document CRM-M-14507- dispute that multiple civil proceedings between the parties are already pending before competent civil courts, wherein issues relating to title, possession and validity of documents are under cons present FIR, proceedings were also initiated before the learned Magistrate, who, upon consideration of the material, did not find it appropriate to direct registration of a case and instead left the parties to pu law. 3. Learned counsel for the petitioners has contended that the petitioners have been falsely implicated and that the present FIR is nothing but an attempt to give a criminal colour to a purely civil dispute. It i between the parties is essentially with regard to property rights and the genuineness of documents, which are already subject matter of civil litigation. It is further contended that the allegations in the FIR are a repetit and that the criminal proceedings have been initiated only to exert pressure upon the petitioners. Learned counsel submits that continuation of the present proceedings would amount to abuse of the process of law. 4. Notice of motio 5. On the asking of the Court, accepts notice on behalf of the State, and Mr. Narendra Hooda, learned Senior Advocate, accepts notice on behalf of respondent No. 2. 6. Mr. Narendra through video conferencing on behalf of respondent No.2/complainant State counsel, have opposed the present petition. It has been contended that the FIR discloses commission of cognizable offences including cheating and forgery and that the police was justified in registering the case. It is further submitted that -2026 (O&M) dispute that multiple civil proceedings between the parties are already pending before competent civil courts, wherein issues relating to title, possession and validity of documents are under consideration. Prior to the registration of the present FIR, proceedings were also initiated before the learned Magistrate, who, upon consideration of the material, did not find it appropriate to direct registration of a case and instead left the parties to pursue their remedies in accordance with Learned counsel for the petitioners has contended that the petitioners have been falsely implicated and that the present FIR is nothing but an attempt to give a criminal colour to a purely civil dispute. It i between the parties is essentially with regard to property rights and the genuineness of documents, which are already subject matter of civil litigation. It is further contended that the allegations in the FIR are a repetit and that the criminal proceedings have been initiated only to exert pressure upon the petitioners. Learned counsel submits that continuation of the present proceedings would amount to abuse of the process of law. Notice of motion. On the asking of the Court, Mr. Sushil Bhardwaj, Addl. A.G., Haryana accepts notice on behalf of the State, and Mr. Narendra Hooda, learned Senior Advocate, accepts notice on behalf of respondent No. 2. Mr. Narendra Hooda, learned Senior Advocat through video conferencing on behalf of respondent No.2/complainant , have opposed the present petition. It has been contended that the FIR discloses commission of cognizable offences including cheating and forgery and that the police was justified in registering the case. It is further submitted that -2- dispute that multiple civil proceedings between the parties are already pending before competent civil courts, wherein issues relating to title, possession and ideration. Prior to the registration of the present FIR, proceedings were also initiated before the learned Magistrate, who, upon consideration of the material, did not find it appropriate to direct registration rsue their remedies in accordance with Learned counsel for the petitioners has contended that the petitioners have been falsely implicated and that the present FIR is nothing but an attempt to give a criminal colour to a purely civil dispute. It is submitted that the controversy between the parties is essentially with regard to property rights and the genuineness of documents, which are already subject matter of civil litigation. It is further contended that the allegations in the FIR are a repetition of earlier disputes and that the criminal proceedings have been initiated only to exert pressure upon the petitioners. Learned counsel submits that continuation of the present proceedings would amount to abuse of the process of law. Mr. Sushil Bhardwaj, Addl. A.G., Haryana accepts notice on behalf of the State, and Mr. Narendra Hooda, learned Senior Advocate, accepts notice on behalf of respondent No. 2. Hooda, learned Senior Advocate, who is appearing through video conferencing on behalf of respondent No.2/complainant and learned , have opposed the present petition. It has been contended that the FIR discloses commission of cognizable offences including cheating and forgery and that the police was justified in registering the case. It is further submitted that dispute that multiple civil proceedings between the parties are already pending before competent civil courts, wherein issues relating to title, possession and ideration. Prior to the registration of the present FIR, proceedings were also initiated before the learned Magistrate, who, upon consideration of the material, did not find it appropriate to direct registration rsue their remedies in accordance with Learned counsel for the petitioners has contended that the petitioners have been falsely implicated and that the present FIR is nothing but an attempt to s submitted that the controversy between the parties is essentially with regard to property rights and the genuineness of documents, which are already subject matter of civil litigation. It is ion of earlier disputes and that the criminal proceedings have been initiated only to exert pressure upon the petitioners. Learned counsel submits that continuation of the present Mr. Sushil Bhardwaj, Addl. A.G., Haryana accepts notice on behalf of the State, and Mr. Narendra Hooda, learned Senior appearing earned , have opposed the present petition. It has been contended that the FIR discloses commission of cognizable offences including cheating and forgery and that the police was justified in registering the case. It is further submitted that TRIPTI SAINI 2026.03.24 09:38 I attest to the accuracy and integrity of this document CRM-M-14507- the allegations are s pendency of civil proceedings does not bar criminal prosecution where ingredients of criminal offences are made out. 7. I have heard learned counsel for the parties and have perused the record with their able assistance. 8. At the very outset, it becomes apparent that the entire controversy between the parties is rooted in a dispute relating to immovable property, involving questions of title, possession and validity of documents such as sale de lease deed dated 23.08.2022. The allegations made in the FIR, though couched in the language of criminal offences, essentially arise out of and are inseparably connected with the determination of civil rights of the parties. The material placed on record clearly indicates that the parties are already engaged in multiple civil litigations, wherein these very issues are subject matter of adjudication before competent courts. 9. It is well settled that criminal proceedings cannot be permitted to b used as a means to settle civil disputes. Where the dispute is predominantly civil in nature and the allegations of criminality are not independent but are intrinsically linked with civil transactions, the Court must exercise caution in allowing criminal prosecution to proceed. The allegations of cheating and forgery in the present case are not based on any independent criminal act divorced from the civil dispute but are founded upon the same set of documents and transactions which are under challenge before the civil court. The determination of whether the lease deed is genuine or otherwise necessarily involves appreciation of evidence and adjudication of rights, which is the domain of the civil court. -2026 (O&M) the allegations are serious in nature and require investigation and that the mere pendency of civil proceedings does not bar criminal prosecution where ingredients of criminal offences are made out. I have heard learned counsel for the parties and have perused the ith their able assistance. At the very outset, it becomes apparent that the entire controversy between the parties is rooted in a dispute relating to immovable property, involving questions of title, possession and validity of documents such as sale de lease deed dated 23.08.2022. The allegations made in the FIR, though couched in the language of criminal offences, essentially arise out of and are inseparably connected with the determination of civil rights of the parties. The material placed on record clearly indicates that the parties are already engaged in multiple civil litigations, wherein these very issues are subject matter of adjudication before competent courts. It is well settled that criminal proceedings cannot be permitted to b used as a means to settle civil disputes. Where the dispute is predominantly civil in nature and the allegations of criminality are not independent but are intrinsically linked with civil transactions, the Court must exercise caution in allowing criminal prosecution to proceed. The allegations of cheating and forgery in the present case are not based on any independent criminal act divorced from the civil dispute but are founded upon the same set of documents and transactions which are under ore the civil court. The determination of whether the lease deed is genuine or otherwise necessarily involves appreciation of evidence and adjudication of rights, which is the domain of the civil court. -3- erious in nature and require investigation and that the mere pendency of civil proceedings does not bar criminal prosecution where ingredients I have heard learned counsel for the parties and have perused the At the very outset, it becomes apparent that the entire controversy between the parties is rooted in a dispute relating to immovable property, involving questions of title, possession and validity of documents such as sale deeds and the lease deed dated 23.08.2022. The allegations made in the FIR, though couched in the language of criminal offences, essentially arise out of and are inseparably connected with the determination of civil rights of the parties. The material placed on record clearly indicates that the parties are already engaged in multiple civil litigations, wherein these very issues are subject matter of adjudication before It is well settled that criminal proceedings cannot be permitted to b used as a means to settle civil disputes. Where the dispute is predominantly civil in nature and the allegations of criminality are not independent but are intrinsically linked with civil transactions, the Court must exercise caution in allowing criminal prosecution to proceed. The allegations of cheating and forgery in the present case are not based on any independent criminal act divorced from the civil dispute but are founded upon the same set of documents and transactions which are under ore the civil court. The determination of whether the lease deed is genuine or otherwise necessarily involves appreciation of evidence and adjudication of rights, which is the domain of the civil court. erious in nature and require investigation and that the mere pendency of civil proceedings does not bar criminal prosecution where ingredients I have heard learned counsel for the parties and have perused the At the very outset, it becomes apparent that the entire controversy between the parties is rooted in a dispute relating to immovable property, involving eds and the lease deed dated 23.08.2022. The allegations made in the FIR, though couched in the language of criminal offences, essentially arise out of and are inseparably connected with the determination of civil rights of the parties. The material placed on record clearly indicates that the parties are already engaged in multiple civil litigations, wherein these very issues are subject matter of adjudication before It is well settled that criminal proceedings cannot be permitted to be used as a means to settle civil disputes. Where the dispute is predominantly civil in nature and the allegations of criminality are not independent but are intrinsically linked with civil transactions, the Court must exercise caution in allowing criminal prosecution to proceed. The allegations of cheating and forgery in the present case are not based on any independent criminal act divorced from the civil dispute but are founded upon the same set of documents and transactions which are under ore the civil court. The determination of whether the lease deed is genuine or otherwise necessarily involves appreciation of evidence and TRIPTI SAINI 2026.03.24 09:38 I attest to the accuracy and integrity of this document CRM-M-14507- 10. A perusal of the record further shows that the p lodged in continuation of the ongoing dispute between the parties and is based on the same set of allegations regarding the property and the lease deed. The change in the person of the complainant does not alter the nature of the disput remains essentially civil. The criminal proceedings, therefore, appear to have been initiated with the object of exerting pressure upon the petitioners and to gain an advantage in the pending civil litigation. 11. It is also a relevant circumstan before Magistrate by filing an application under section 175(3) BNSS in respect of the same dispute did not result in any direction for registration of a criminal case, which further indicates that the matter primarily determinative in itself, this aspect lends support to the conclusion that the present attempt to invoke criminal jurisdiction is not bona fide. 12. In view of the above, this Court is of the considered opinion that the present case is a clear instance where a civil dispute has been sought to be given a criminal colour. Continuation of the criminal proceedings in such circumstances would amount to abuse of the process of law and would not serve the ends of justice. 13. Accordingly, FIR No. 15 dated 11.02.2026 registered at Police Station Mohammadpur Ahir, District Nuh, Haryana and all consequential proceedings arising therefrom are hereby quashed. 14. All pending miscellaneous application(s), if any, stands disposed of March 23, 2026 tripti Whether speaking/non Whether reportable -2026 (O&M) A perusal of the record further shows that the p lodged in continuation of the ongoing dispute between the parties and is based on the same set of allegations regarding the property and the lease deed. The change in the person of the complainant does not alter the nature of the disput remains essentially civil. The criminal proceedings, therefore, appear to have been initiated with the object of exerting pressure upon the petitioners and to gain an advantage in the pending civil litigation. It is also a relevant circumstance that earlier proceedings initiated before Magistrate by filing an application under section 175(3) BNSS in respect of the same dispute did not result in any direction for registration of a criminal case, which further indicates that the matter primarily determinative in itself, this aspect lends support to the conclusion that the present attempt to invoke criminal jurisdiction is not bona fide. In view of the above, this Court is of the considered opinion that the resent case is a clear instance where a civil dispute has been sought to be given a criminal colour. Continuation of the criminal proceedings in such circumstances would amount to abuse of the process of law and would not serve the ends of Accordingly, FIR No. 15 dated 11.02.2026 registered at Police Station Mohammadpur Ahir, District Nuh, Haryana and all consequential proceedings arising therefrom are hereby quashed. All pending miscellaneous application(s), if any, stands disposed of Whether speaking/non-speaking : Speaking Whether reportable : Yes/No -4- A perusal of the record further shows that the present FIR has been lodged in continuation of the ongoing dispute between the parties and is based on the same set of allegations regarding the property and the lease deed. The change in the person of the complainant does not alter the nature of the dispute, which remains essentially civil. The criminal proceedings, therefore, appear to have been initiated with the object of exerting pressure upon the petitioners and to gain an ce that earlier proceedings initiated before Magistrate by filing an application under section 175(3) BNSS in respect of the same dispute did not result in any direction for registration of a criminal case, which further indicates that the matter primarily involves civil issues. Though not determinative in itself, this aspect lends support to the conclusion that the present attempt to invoke criminal jurisdiction is not bona fide. In view of the above, this Court is of the considered opinion that the resent case is a clear instance where a civil dispute has been sought to be given a criminal colour. Continuation of the criminal proceedings in such circumstances would amount to abuse of the process of law and would not serve the ends of Accordingly, FIR No. 15 dated 11.02.2026 registered at Police Station Mohammadpur Ahir, District Nuh, Haryana and all consequential proceedings All pending miscellaneous application(s), if any, stands disposed of (MANDEEP PANNU) JUDGE : Speaking : Yes/No resent FIR has been lodged in continuation of the ongoing dispute between the parties and is based on the same set of allegations regarding the property and the lease deed. The change e, which remains essentially civil. The change e, which remains essentially civil. The criminal proceedings, therefore, appear to have been initiated with the object of exerting pressure upon the petitioners and to gain an ce that earlier proceedings initiated before Magistrate by filing an application under section 175(3) BNSS in respect of the same dispute did not result in any direction for registration of a criminal case, involves civil issues. Though not determinative in itself, this aspect lends support to the conclusion that the present In view of the above, this Court is of the considered opinion that the resent case is a clear instance where a civil dispute has been sought to be given a criminal colour. Continuation of the criminal proceedings in such circumstances would amount to abuse of the process of law and would not serve the ends of Accordingly, FIR No. 15 dated 11.02.2026 registered at Police Station Mohammadpur Ahir, District Nuh, Haryana and all consequential proceedings All pending miscellaneous application(s), if any, stands disposed of. TRIPTI SAINI 2026.03.24 09:38 I attest to the accuracy and integrity of this document