Supreme Court Quashes Lucknow FIR Over a Land Joint Venture, Holding the Dispute Civil

On 25 February 2026, a Bench of the Supreme Court comprising Justice P.S. Narasimha and Justice Manoj Misra allowed an appeal against an order of the Allahabad High Court dated 30 July 2021 in Misc. Bench No. 16314 of 2021, which had dismissed a writ petition seeking to quash FIR No. 0112 of 2021 registered at Police Station Hazratganj, Lucknow, under sections 406, 420, 467, 468 and 471 of the Indian Penal Code.

The appellants had entered into a joint venture agreement dated 16 August 2010 with Motor General Sales Ltd., giving it development rights over land in Azad Nagar, Kanpur. On 14 March 2021, the company lodged the FIR, alleging false representations about the title to the land and litigation concerning it, non-fulfilment of contractual obligations, non-refund of security money, and the use of a false document. The judgment records that the High Court had dismissed the writ petition in limine.

Writing for the Bench, Justice Misra held that where the cause espoused in an FIR is essentially civil, the court must assess whether it has been given a cloak of a criminal offence, and may consider the admitted facts and documents recited in the FIR as well as its contents. The Court found no false representation in the agreement, held that the security money was adjustable against the appellants' share rather than refundable, and held that a letter could not be called forged merely because the issuing office could not trace it ten or eleven years later.

The Court recorded that the High Court "did not take pains to carefully read the FIR and consider the admitted documents including the JVA" to find out whether a cognizable offence was made out. It set aside the High Court's order and quashed the FIR and all proceedings arising from it.