In a landmark decision, the Supreme Court of India has taken a stern stand against unscrupulous litigants, emphasizing the need to deter those who burden the justice system with frivolous criminal proceedings in matters that are fundamentally civil in nature. The bench, comprising Justices Vikram Nath and Rajesh Bindal, not only quashed the criminal proceedings but also imposed substantial costs of ₹25 lakh on the litigant responsible for initiating the questionable legal actions.
The judgment underscores the court's commitment to ensuring that litigants who engage in forum hunting, concealment, and falsehoods do not escape consequences. The bench expressed its discontent with the misuse of judicial remedies and highlighted the urgency to address such litigation firmly.
The case in question originated from a dispute over a share-pledge agreement and loan disbursement. Despite the parties involved being based in Delhi, the complainant filed a First Information Report (FIR) in Noida, Uttar Pradesh, a move criticized by the Supreme Court as an inappropriate exercise of jurisdiction. The court found that the criminal proceedings were initiated with incorrect facts and frivolous reasons, revealing a motive for personal vengeance rather than a pursuit of justice.
The Supreme Court criticized the litigant's attempt to turn a civil matter into a criminal one, emphasizing that such actions not only overburden the criminal justice system but also violate principles of fairness and right conduct in legal matters. The court noted that the parties had already engaged in arbitration, execution, and enforcement proceedings before the Delhi High Court, making the criminal proceedings unnecessary and an abuse of the court's process.
Senior Advocates Kapil Sibal, Nakul Dewan, and Anjana Prakash represented the appellants, Dinesh and Rajesh Gupta, while Senior Advocate Vikas Singh appeared for the respondent-complainant, Karan Gambhir.
The court highlighted that the imposition of costs was necessary to address the misuse of judicial remedies, which erodes public trust in the judiciary. The costs, amounting to ₹25 lakh, were directed to be equally paid to the Supreme Court Bar Association (SCBA) and the Supreme Court Advocates-on-Record Association (SCAORA).
Case: Dinesh Gupta vs The State of Uttar Pradesh & Anr,
CRIMINAL APPEAL NO(S). OF 2024 (Arising out of S.L.P.(Crl.) No.3343 of 2022).
Click to read/download judgment.
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