The Supreme Court overturned a decision by the Madhya Pradesh High Court, which had quashed an FIR related to a property dispute, holding that the High Court erred in categorizing the dispute as purely civil. The Court emphasized that the allegations in the FIR indicated serious criminal offenses, which needed to be investigated on their merits. The Supreme Court directed the State of Madhya Pradesh to proceed with the FIR and any consequential criminal proceedings.

1. Background

• The appeals arose from a common order by the Madhya Pradesh High Court, which quashed an FIR and the related criminal proceedings, labeling the matter as a civil dispute.
• The FIR in question was registered based on a complaint that private individuals had fraudulently sold government land in Khategaon, Dewas.

2. Dispute and Litigation History

• The property in question was initially involved in a civil suit, where the title was contested. The courts, including the High Court, had upheld that the property vested in the State of Madhya Pradesh.
• Despite this, subsequent investigations revealed fraudulent transactions regarding the property, leading to the filing of the FIR.

3. High Court's Order

• The High Court quashed the FIR on the premise that the dispute was civil, not criminal, in nature, and that the State had failed to prove its title over the property.

4. Supreme Court's Analysis

• The Supreme Court found that the High Court had erred in its assumption regarding the State's title.
• The Court highlighted that revenue records could not confer title, and criminal allegations such as forgery and fraud warranted proper investigation.

5. Key Legal Principles

• The Court referenced the principles laid out in State of Haryana v. Bhajan Lal, emphasizing that criminal proceedings should not be quashed if the allegations reveal a cognizable offense.
• It also referred to Mohd. Ibrahim v. State of Bihar, underscoring that civil disputes should not be dressed as criminal cases, but also that legitimate criminal allegations should be pursued.

6. Conclusion and Directions

• The Supreme Court set aside the High Court’s order and reinstated the FIR and criminal proceedings.
• The Court directed the State of Madhya Pradesh to proceed with the FIR in accordance with the law, clarifying that the observations made in this judgment were solely for testing the correctness of the High Court's order and should not affect the subsequent criminal proceedings.