Brief Facts:
In the case of Shantilata Mohanty and Anr. vs. State of Odisha and Others, the petitioners sought the quashing of Bhadrak Town P.S. Case No. 202 of 2016, which involved charges under Sections 341, 323, 294, and 506 read with Section 34 of the IPC. The case stemmed from a dispute over property, which was the subject of both civil litigation and a criminal complaint. The petitioners had already won a civil suit regarding the probate of a will, but the informants, who lost that case, filed a criminal complaint alleging that the petitioners had forcibly taken possession of the property.
Point of Law:
The primary legal issue was whether the criminal proceedings could continue when the dispute was civil in nature. The petitioners argued that the criminal complaint was an abuse of the legal process, as the matter had already been addressed in civil court, and the allegations of criminal conduct were baseless and intended to harass them.
High Court Ruling:
The Orissa High Court, following established legal precedents, quashed the criminal proceedings. The court held that the case was essentially a civil dispute that had been improperly framed as a criminal matter. Citing various Supreme Court rulings, the court emphasised that criminal liability should not be imposed in disputes of a civil nature and that using criminal proceedings to settle civil disputes constitutes an abuse of legal process. The petition was allowed, and the criminal case was quashed.