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

How a land dispute became a criminal accusation

The complainant said that property once held by the appellant's parents had been transferred through powers of attorney and sale deeds even though title to part of the land had passed to the government. A civil suit concerning the land was already pending, while the criminal case raised a narrower question about whether the material in the FIR made the appellant's own conduct criminal.

The appellant had succeeded to a claimed interest after her father's death, and the first FIR referred to her without listing her as an accused. She was subsequently named in another FIR, which the Court compared with the first to determine whether the later accusation identified a newly discovered act rather than merely adding a person to an existing account of the transfers.

Ownership claims are different from acts of deception

The land complaint treated registered powers of attorney as fake or fraudulent, but the Court observed that the alleged documents were said to have been executed by the mother and daughter themselves. Its concern was with the logic of the accusation as presented, since a dispute about what property an instrument could validly convey did not explain why execution of that instrument, on these allegations, amounted to forgery by the appellant.

The Court considered the further allegation that the sale deeds referred to a jamabandi and that the vendors had conveyed more property than they owned. Even if those assertions raised a serious issue about title or the rights of a purchaser, the judgment found that they did not establish criminal liability of this appellant at the instance of a person claiming occupation of the land.

This distinction does not settle who owned the contested portion or whether any purchaser could seek a remedy. It explains why a disagreement over the reach of succession, authority to convey and the effect of a sale deed could not be treated as proof of a particular accused person's criminal conduct without facts connecting that person to an offence.

What the second FIR added to the property dispute

The appellant submitted that no new evidence had emerged after the first FIR, whereas the State asserted that investigation had disclosed her role. The Court read the two accounts and found no additional material establishing her culpability, apart from a reference to a jamabandi which, according to the judgment, did not exist.

Her earlier mention therefore became relevant in combination with what was missing from the later report. The Court did not hold that police investigation must stop at the names in an initial complaint, but it required a factual basis for making a person answer a criminal allegation when the later account otherwise repeated the same property story.

The boundary drawn by the order

Because the complainant was already pursuing a civil suit and the FIR disclosed no criminality on the appellant's part, the Supreme Court rejected use of the criminal case to press the land dispute against her. It allowed her appeal and quashed FIR No. 588 at Faridabad Central Police Station and its consequential proceedings only in relation to the appellant.

The order leaves the civil contest to its own process and says nothing final about proceedings against other persons. Its useful distinction is between transactions whose legal effect may be disputed and allegations that actually describe criminal behaviour by the individual seeking quashing.