Sunisha Anand v. State of Haryana and Another · 2026 INSC 530

Why the Court compared the two FIRs

The appellant was mentioned in the first report about disputed land transfers without being made an accused, but a later FIR placed her among those facing the criminal allegation. Because the State said the investigation had revealed her role, the Court examined whether the subsequent account actually identified a fresh fact connecting her with fraudulent conduct.

It found substantially the same accusation in both accounts, with a reference to a jamabandi which the judgment said did not exist. That finding mattered because adding the appellant to the array of accused required some factual explanation on this record, not merely a new label attached to the earlier property narrative.

Why execution of the documents mattered

The complainant alleged that powers of attorney had been fabricated to support transfers of land that the appellant's family did not fully own. The Court asked how the instruments could be called fake or fraudulent on the accusation as framed when the persons challenged were themselves said to have executed the powers of attorney.

This reasoning addressed a particular mismatch between the allegation and the described act. It did not certify the legal effectiveness of every instrument or decide the ownership of the land, but it prevented an unsupported inference of forgery from the existence of contested conveyancing documents.

Why a title defect did not answer the criminal question

The Court next separated the possibility of conveying more land than one owns from criminal liability of the appellant toward this complainant. A sale deed containing a jamabandi reference, even when combined with an allegation that the vendors lacked title to part of the property, did not identify the criminal act the appellant was supposed to have committed in the factual setting presented.

The complainant claimed occupation of the land rather than purchase under the challenged conveyances, while other persons had received the property through later transactions. In observing that a complaint about overconveyance would, if made on these facts, belong to the purchasers, the Court explained why the present allegation did not become a criminal accusation against the appellant merely through disagreement about title.

Why the civil proceedings affected the result

The land dispute had already produced a civil suit brought by the complainant. That existing proceeding gave the Court the setting for its conclusion that criminal process should not be used to advance an essentially civil claim when the FIR furnished no separate basis for accusing the appellant of an offence.

The Court did not state that every transaction litigated in a civil suit is immune from criminal scrutiny. Its conclusion followed from the particular missing allegation against this appellant and from the failure of the asserted document and title irregularities to fill that gap.

Why the relief was limited to one person

The Supreme Court allowed the appeal and quashed FIR No. 588 and its consequential proceedings only insofar as the appellant was concerned. Since the reasoning addressed the lack of criminality alleged against her, it could not automatically decide the position of others who were said to have executed documents or received property.

The limited order also left the title controversy unresolved. Its reasoned result was removal of an unsupported criminal case against one individual while leaving the civil forum and the positions of other participants outside the scope of that relief.