Quashing of FIR under IPC Sections 120-B, 420, 467, 468, 471: Punjab and Haryana High Court Rules Against Misuse of Criminal Law in Civil Disputes

By Rohit Thakur , Legal Awareness & Information.

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23 February 2026

What happened

Section 482 CrPC

Subject : Criminal Law - Quashing of FIR

Quashing of FIR under IPC Sections 120-B, 420, 467, 468, 471: Punjab and Haryana High Court Rules Against Misuse of Criminal Law in Civil Disputes

Weaponizing Criminal Law: High Court Halts Abuse of Process in Real Estate Dispute

In a resounding message against the growing trend of turning civil disputes into criminal litigation, the Punjab and Haryana High Court at Chandigarh has quashed an FIR that sought to leverage criminal charges to settle a property-related contract dispute. The case, Parveen Nain and Ors. v. State of Haryana , highlights the judiciary's firm stance against the misuse of the Indian Penal Code ( IPC ) as a tool for financial coercion.

The Backdrop: A Contract Gone Sour

At the heart of the dispute was an agreement to sell land owned by the complainant, Ajay Kumar. The petitioners argued that they had entered into an agreement to purchase the land, but the transaction became contentious when the complainant failed to execute the sale deed, eventually selling the property to a third party, M/s Celestial Valley LLP.

When the petitioners initiated civil proceedings for specific performance of the contract, the complainant retaliated with a criminal complaint alleging forgery, claiming that the original agreement had been altered to reflect a lower sale consideration. The police registered an FIR under Sections 120-B, 420, 467, 468

misuse of criminal law - civil contractual dispute - abuse of legal process - forgery allegations - sale consideration

#QuashingOfFIR #CriminalJurisprudence

Case Title: Parveen Nain vs State of Haryana - 2022 Supreme(Online)(P&H) 77097

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