Supreme Court Disposes Special Leave Petition in FIR Quashing Case -- Grants Bail to Petitioners in Chargesheet-Filed Case -- Directs Expeditious Disposal of Criminal Proceedings


CASE NOTE & SUMMARY

The Supreme Court disposed of a Special Leave Petition filed by accused persons seeking quashing of FIR No. 396 of 2025 registered at Police Station Tajganj, Agra -- The High Court had declined to quash the FIR and directed petitioners to appear before the Trial Court -- The Supreme Court noted that three different cases were filed on similar facts, with two already stayed or withdrawn -- The chargesheet in the present case concluded that allegations were not substantiated -- The Court allowed impleadment of the Interim Resolution Professional, directed closure of other proceedings, and granted bail to petitioners upon appearance before jurisdictional court -- The Court emphasized cooperation for expeditious disposal of the case


HEADNOTE

The Supreme Court disposed of a Special Leave Petition challenging the High Court's refusal to quash FIR No. 396 of 2025 -- The petitioners contended the dispute was civil in nature and filed with mala fide intention -- The Court noted three different cases were filed on similar facts, with two already stayed or withdrawn -- The chargesheet in the present case concluded allegations were not substantiated -- The Court directed closure of other proceedings and granted bail to petitioners upon appearance before jurisdictional court -- The Interim Resolution Professional was impleaded to represent the corporate complainant -- The Court emphasized expeditious disposal of the case


ISSUE OF CONSIDERATION

Whether the FIR registered against the petitioners should be quashed on grounds of mala fide intention and civil nature of dispute, and whether bail should be granted to the petitioners

FINAL DECISION

The Supreme Court disposed of the Special Leave Petition -- Directed closure of other proceedings -- Granted bail to petitioners upon appearance before jurisdictional court within one month -- Allowed impleadment of Interim Resolution Professional -- Directed expeditious disposal of the case

Citation: 2026 LawText (SC) (01) 24

Case Number: Special Leave Petition (Crl.) No. 11375 of 2025

Date of Decision: 2026-01-06

Case Title: Whether the FIR registered against the petitioners should be quashed on grounds of mala fide intention and civil nature of dispute, and whether bail should be granted to the petitioners

Before Judge: Ahsanuddin Amanullah, K. Vinod Chandran

Equivalent Citations: 2026 INSC 28

Advocate(s): Shri Ashish Pandey, Shri Ardhendumauli Kumar Prasad

Appellant: Smt. Shalini Bhateja & Anr.

Respondent: The State of U.P. & Ors.

Nature of Litigation: Criminal proceedings seeking quashing of FIR alleging cheating and conspiracy

Remedy Sought: Petitioners sought quashing of FIR No. 396 of 2025 and relief from criminal proceedings

Filing Reason: Petitioners alleged mala fide intention in registering FIR and contended dispute was civil in nature

Previous Decisions: High Court declined to quash FIR and directed petitioners to appear before Trial Court within 60 days

Issues: Whether the FIR should be quashed on grounds of civil nature of dispute and mala fide intention Whether bail should be granted to the petitioners in view of filed chargesheet

Submissions/Arguments: Petitioners argued dispute was civil in nature and multiple cases filed on same facts Respondent argued cheating was involved through surreptitious credit to another account and persistent demands for refund

Ratio Decidendi: When chargesheet has been filed concluding allegations are not substantiated, and other parallel proceedings are stayed or withdrawn, petitioners should be granted bail rather than taken into custody -- The court should ensure expeditious disposal while protecting rights of accused

Judgment Excerpts: "The petitioners shall appear before the jurisdictional court within a period of one month from today upon which they shall be granted bail" -- Para 8 "The chargesheet has been filed, in which circumstance, there is no reason why the petitioners should be taken into custody" -- Para 7

Procedural History: FIR registered on 09.06.2025 -- High Court declined quashing on 2025 -- Special Leave Petition filed before Supreme Court -- Chargesheet filed on 11.09.2025 -- Supreme Court disposed petition on 06.01.2026

Acts and Sections:
  • Code of Criminal Procedure, 1973 (CrPC): Section 156(3), Section 173(4)