Civil Dispute Not to Be Cloaked with Criminality: Supreme Court Quashes FIR Against Doctors

In a landmark judgment, the Supreme Court of India today quashed an FIR against two doctors, Dr. Sonia Verma and another, underlining the vital distinction between civil disputes and criminal proceedings. The bench comprising Justices Vikram Nath and Satish Chandra Sharma delivered the verdict in the case titled "Dr. Sonia Verma & Anr. Versus The State of Haryana & Anr.", emphasizing the misuse of criminal process in matters predominantly civil in nature.

The Apex Court's decision centered on the critical assessment of whether a dispute essentially of a civil nature should be dragged into the realm of criminal litigation. The ruling underscores the judicial standpoint against the abuse of criminal process when a parallel civil remedy exists.

The case arose from FIR No. 375/2022 involving allegations of fraud, criminal conspiracy, and forgery against the appellants, who are doctors owning a hospital. The FIR was filed by Respondent No. 2, claiming forgery in a sale deed and usurpation of property. The appellants had earlier filed a civil suit for the same property, asserting their ownership based on consecutive sale deeds.

Civil Nature of Dispute: The Court observed that the heart of the matter lies in the civil realm, mainly concerning the validity of a sale deed. It was noted that the appellants had already sought a civil remedy, rendering the criminal complaint somewhat redundant and an abuse of process.

Abuse of Criminal Justice System: The judgment referred to the precedent set in "Paramjeet Batra v. State of Uttarakhand & Ors.", stressing the importance of distinguishing civil disputes from criminal offences. The Court criticized the use of a criminal complaint to challenge the validity of a sale deed, which is essentially a matter for civil courts.

Quashing of FIR: In view of the facts and circumstances, and considering that the criminal proceedings were primarily an attempt to cloud a civil dispute with criminality, the Court directed the quashing of the FIR against the appellants.

The Supreme Court allowed the appeal, setting aside the impugned order of the High Court, and quashed all criminal proceedings arising from the FIR. It was further clarified that this order shall not impact the ongoing civil suit, which is to be decided independently as per law.

Date of Decision: March 7, 2024

Dr. Sonia Verma & Anr. vs. The State of Haryana & Anr.