Manna Lal v. State of Chhattisgarh

Chhattisgarh HC27 Oct 2025CRMP/499/2025

Case brief

AI extract

What is this about?

Quashment of FIR and consequential criminal proceedings upon mediation settlement; inherent jurisdiction under Section 528 BNSS 2023; FIR No. 195/2021, Police Station Bilha, District Bilaspur; offences under Sections 420 and 34 IPC; Criminal Case No. 1457/2024 before JMFC Bilha; cognizance order dated 18.10.2024; mediation report dated 27/10/2025; compromise between parties; CRMP Nos. 499 and 428 of 2025; High Court of Chhattisgarh at Bilaspur.

What did the court decide?

Both CRMPs allowed; FIR No. 195/2021, the charge-sheet, the cognizance order dated 18.10.2024 in Criminal Case No. 1457/2024 and all consequential proceedings quashed, subject to fulfillment of the terms and conditions of the mediation agreement. ¶¶36

Manna Lal Vs State of Chhattisgarh — Cheating and Forgery | Chhattisgarh HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the FIR No. 195/2021, the charge-sheet, the cognizance order dated 18.10.2024 in Criminal Case No. 1457/2024 (offences under Sections 420 and 34 IPC) and all consequential proceedings should be quashed in exercise of inherent jurisdiction under Section 528 BNSS, 2023, in view of the settlement between the parties arrived at through mediation.

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Court's answer

Having considered the facts and circumstances, the Court deemed it appropriate to exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

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Ratio / Principle

Subject to fulfillment of the terms and conditions of the mediation agreement, FIR No. 195/2021 registered at Police Station Bilha, District Bilaspur (C.G.), the charge-sheet filed thereupon, the cognizance order dated 18.10.2024 passed by the Judicial Magistrate First Class, Bilha, in Criminal Case No. 1457/2024, together with all consequential proceedings arising therefrom, stand quashed.

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Key takeaways

The quashed proceedings related to the offence punishable under Section 420 read with Section 34 of the Indian Penal Code, and the quashment extends to all consequential proceedings arising therefrom.ratio¶¶35

Detailed headnote1 paragraphs

Chhattisgarh High Court (Bilaspur), common order dated 28/10/2025 by Chief Justice Ramesh Sinha (with Bibhu Datta Guru, Judge) allowing CRMP Nos. 499 and 428 of 2025 filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 seeking quashment of FIR No. 195/2021 of Police Station Bilha, District Bilaspur, the charge-sheet thereon, and the cognizance order dated 18.10.2024 passed by the Judicial Magistrate First Class, Bilha, in Criminal Case No. 1457/2024, for offences punishable under Section 420 read with Section 34 IPC. By order dated 19/09/2025 the Court had referred the parties to the Mediation Centre; the mediation report dated 27/10/2025 recorded that the matter stood settled. Exercising inherent jurisdiction, the Court quashed the FIR, the charge-sheet, the cognizance order and all consequential proceedings, subject to fulfillment of the terms and conditions of the mediation agreement.

2025:CGHC:52451-DB

NAFR

HIGH COURT OF CHHATTISGARH AT BILASPUR

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RAHUL JHA

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Digitally signed by RAHUL JHA Date: 2025.10.31 18:30:07 +0530

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CRMP No. 499 of 2025

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Manna Lal S/o Baisakhu Lal Aged About 53 Years Caste- Gond ( Aadiwasi ) R/o Pendarwa, Post Hirri, Tahsil- Bilha, District- Bilaspur ( C.G. ).

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Petitioner(s)

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Versus

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1 - State Of Chhattisgarh Thourgh- Police Station Bilha, District Bilaspurf ( C.G. ).

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2 - Ratan Lal Gupta ( Died ) Through- His Legal Heris Ashutosh S/o Late Ratan Lal Gupta, Aged About 29 Years, R/o Tifra Main Road, Bilaspur DistBilaspur ( C.G. ).

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Respondent(s)

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AND

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CRMP No. 428 of 2025

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Shiv Kumar Agrawal S/o Madan Lal Agrawal Aged About 55 Years R/o Ward No. 4, Bilha, District- Bilaspur, C.G.

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--- Petitioner(s)

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Versus

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1 - State Of Chhattisgarh Through - Police Station Bilha, District- Bilaspur, C.G.

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2 - Ratan Lal Gupta (Died) Through His Legal Heirs Ashutosh S/o Late Ratan Lal Gupta Aged About 29 Years R/o Tifra Main Road, Bilaspur Dist. Bilaspur, C.G. (Complainant)

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Respondent(s)

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(Cause-title taken from Case Information System)

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For Petitioner(s) : Mr. Amit Kumar, Advocate For State : Mr. Shaleen Singh Baghel, Dy. GA

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For Respondent No. 2 : Mr. C.K. Sahu, Advocate Hon'ble Shri Ramesh Sinha, Chief Justice

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Hon’ble Shri Bibhu Datta Guru, Judge Order on Board

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Per Ramesh Sinha, Chief Justice

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28/10/2025

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Since both the CRMPs have been filed seeking quashment of the same FIR and the proceedings arising therefrom, they are being considered together and decided by this common order.

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The instant CRMPs under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 has been filed for the following prayer:-

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“It is, therefore, prayed that this Hon'ble Court may kindly be pleased to exercise its inherent jurisdiction under Section 528 of B.N.S.S., 2023 and in exercise thereof call for the records, if necessary, admit the petition and may kindly be pleased to allow this petition and to quashing of the FIR no. 195/2021 as well as charge sheet filed before the learned trial court which is registered as criminal case no. 1457/2024 on 18.10.2024 and cognizance order dated 18.10.2024, for offence punishable under Section 420 read with section 34 of the I.P.C by the Police Station Bilha, District Bilaspur (C.G.), Cognizance Order (First Order Sheet) dated 18.10.2024 in Criminal Case No. 1457/2024 which is pending before the Judicial Magistrate First Class, Bilha, Bilaspur District Bilaspur (C.G.) and (if any), all consequent proceedings incidental & accidental thereto and orders prejudicial to the petitioner herein and/or pass such other orders in favour of the petitioner as this Hon'ble Court may deem it fit in the facts and circumstances of the case ”

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This Court, vide its order dated 19/09/2025, after considering the possibility of compromise, directed the parties to appear before the Mediation Centre for amicably settling the matter and further directed that the matters be listed before this Court along with the mediation report, if any final settlement was arrived at. The mediation report dated 27/10/2025 has since been filed before this Court wherein it has been reported that the matter is settled.

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Learned counsel for the petitioners as well as for Respondent No. 2 have submitted that the mediation has been successful.

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Having considered the facts and circumstances of the case, this Court deems it appropriate to exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, and accordingly, it is ordered that, subject to the fulfillment of the terms and conditions of the mediation agreement, the FIR No. 195/2021 registered at Police Station Bilha, District Bilaspur (C.G.), the charge-sheet filed thereupon, as well as the cognizance order dated 18.10.2024 passed by the Judicial Magistrate First Class, Bilha, in Criminal Case No. 1457/2024, together with all consequential proceedings arising therefrom, for the offence punishable under Section 420 read with Section 34 of the Indian Penal Code, stand quashed.

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Accordingly, the CRMPs stand allowed .

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Sd/Sd/-

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(Bibhu Datta Guru) (Ramesh Sinha) Judge Chief Justice

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Rahul/Gowri

Manna Lal v. State of Chhattisgarh

Case brief

What is this about?

What did the court decide?

Manna Lal v. State of Chhattisgarh

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

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