Sunisha Anand vs State Of Haryana

2026 INSC 494 Non-Reportable

IN THE SUPREME COURT OF INDIA CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO.2457 OF 2026

Sunisha Anand ...Appellant Versus

State of Haryana & Anr.

...Respondents

ORDER

The above appeal is filed by one of the applicants before the

High Court seeking interference to FIR No.588 dated 02.06.2018,

registered at the Police Station, Faridabad Central. The impugned

common order in two petitions declined relief holding that though

the dispute primarily pertains to land and a civil suit has already

been filed there are criminal elements, which cannot be ignored

since the accused persons are alleged to have knowingly

prepared and executed forged General Power of Attorneys

(GPAs), despite being aware that a portion of the land in question

Signature Not Verified have been transferred to the State of Uttar Pradesh. Digitally signed by Deepak Guglani Date: 2026.05.15 17:54:57 IST Reason: Page 1 of 4 Crl. A. No.2457 of 2026

2. Sri Siddharth Luthra, learned Senior Counsel pointed out

that in the First FIR though the name of the appellant herein is

mentioned she was no arrayed as an accused. By a

supplementary FIR, the appellant has been arrayed, though there

is no material seen to have been unearthed on the further

investigation after the first FIR. The decision in Mariam

Fasihuddin & Anr. v. State by Adugodi Police Station & Anr.1 is

relied on, wherein submission of supplementary report in the

absence of new evidence was frowned upon.

3. Sri Abhinav Bajaj, learned Additional Attorney General for

the respondent-State argues that there is no reason to quash the

FIR and the appellant has been arrayed subsequently by reason

of the details revealed on investigation. The first FIR was

registered and in the course of the investigation, the appellant’s

role was also disclosed and hence she was arrayed as an accused.

4. The allegation as seen from the first FIR is that the appellant

is the daughter of one Onkar Singh and Mohinder Kaur, who are

title holders to certain properties. Onkar Singh having died, the

appellant also obtained right over the said property by way of

1 (2024) 11 SCC 733

Page 2 of 4 Crl. A. No.2457 of 2026 succession. It is the allegation that the mother of the appellant got

fake GPAs executed and registered on the strength of which lands

were transferred to the accused Pratap Singh and Prem Pal, who

entered into further conveyances with respect to the same

properties. It was also alleged that the appellant and her mother

did not have title over the entire properties, the title to a portion

of which having been divested by transfer to the Government. In

the first FIR, the first information statement refers to the appellant,

but the appellant was not made one of the accused. In the second

FIR produced as Annexure P10 the very same allegations are

levelled and there is nothing unearthed to find the culpability of

the appellant herein but for a reference to a jamabandi having

been referred to in the document, which in fact does not exist.

5. As we see from the records, the de-facto complainant, the

second respondent is said to be in possession of certain lands,

which was the subject matter of the transaction alleged. The

appellant along with her mother is said to have executed a GPA

on the strength of which and by a separate sale deed having

conveyed certain properties to the accused. We are unable to

comprehend how the GPA can be termed as fake or fraudulent,

when the very contention is that the GPAs were executed by the

Page 3 of 4 Crl. A. No.2457 of 2026 mother and daughter. Further the jamabandi having been noticed

in the sale deed or the vendors having conveyed more property

than they had title over cannot lead to any criminal liability as

such; which if at all alleged, should be by the purchasers. Here,

a person alleged to be in occupation of a land has filed the

complaint and we are unable to find any reason on facts as

disclosed from the FIR to even allege any criminality on the

appellant herein. Admittedly, there is a civil suit pending as

initiated by the de-facto complainant. Criminal law cannot be

used to further the cause in a purely civil dispute.

6. We, hence, quash FIR No.588 dated 02.06.2018, Annexure

P10, registered at Faridabad Central Police Station, insofar, the

appellant herein is concerned.

7. The above appeal is allowed.

8. Pending application(s), if any, shall stand disposed of.

……...…….……………………. J.

(SANJAY KUMAR)

...………….……………………. J.

(K. VINOD CHANDRAN) NEW DELHI;

May 11, 2026.

Page 4 of 4 Crl. A. No.2457 of 2026