Allowed¶10

Satinder Pal Singh v. State of Punjab and Anr.

Punjab & Haryana HC27 Aug 2025CRM-M/3900/2020

Case brief

AI extract

What is this about?

FIR quashing - subsequent purchaser for consideration of vehicle - complaint by Punjab Gramin Bank against vendor Munish Bahri for unpaid car loan and sale without intimation to Bank - loan settled, No Dues/No Objection Certificate issued, HDFC Bank loan closure letter dated 21.03.2018 - Sections 406, 420, 465, 468, 471 IPC - PS Navi Baradari, Jalandhar City - abuse of process of law - CRM-M- 3900 of 2020 - VINOD S. BHARDWAJ - August 27, 2025.

What did the court decide?

Quashing of FIR No. 152 dated 25.05.2016 (Annexure P-1) under Sections 406, 420, 465, 468, 471 IPC registered at Police Station Navi Baradari, Jalandhar City, Police Commissionerate Jalandhar, Punjab, along with all other consequential proceedings arising therefrom. ¶10

Satinder Pal Singh Vs State of Punjab and Anr. — Cheating and Forgery | Punjab & Haryana HC (2025)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the continuation of criminal proceedings arising from FIR No. 152 dated 25.05.2016 against the petitioner, a subsequent purchaser for consideration of the vehicle, would be an abuse of the process of law, given that the loan dispute of the vendor with the respondent-Bank stands settled and the Bank has no transaction with the petitioner.

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Court's answer

There being no pending dispute inter se the petitioner and the respondent-Bank and the entire loan amount of respondent No.2-Bank having already been settled, the continuation of the proceedings against the petitioner, who is a subsequent purchaser for consideration, would be an abuse of the process of law.

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Ratio / Principle

The present petition is allowed and FIR No. 152 dated 25.05.2016 (Annexure P-1) under Sections 406, 420, 465, 468, 471 IPC registered at Police Station Navi Baradari, Jalandhar City, Police Commissionerate Jalandhar, Punjab, along with all other consequential proceedings arising therefrom, stands quashed.

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Detailed headnote1 paragraphs

Criminal petition CRM-M- 3900 of 2020 allowed; FIR No. 152 dated 25.05.2016 (Annexure P-1) under Sections 406, 420, 465, 468, 471 IPC, registered at Police Station Navi Baradari, Jalandhar City, Police Commissionerate Jalandhar, Punjab, and all consequential proceedings arising therefrom quashed. The FIR arose from a complaint by the Manager, Punjab Gramin Bank, Waryana, Jalandhar against Munish Bahri, vendor and first owner of the car, alleging non-repayment of a car loan and sale of the car without intimation to the Bank. The petitioner, a subsequent purchaser for consideration, had paid the entire sale consideration, obtained execution of transfer documents and a No Dues Certificate/No Objection Certificate from Punjab Gramin Bank, and had separately hypothecated the car with HDFC Bank and cleared that loan (closure letter dated 21.03.2018). Learned counsel for the respondent-Bank confirmed that the entire loan amount stands settled, nothing is outstanding against the petitioner, and the Bank had no transaction with the petitioner. Holding that continuation of the proceedings against such a subsequent purchaser would be an abuse of the process of law, the Court (VINOD S. BHARDWAJ, Judge; decision dated August 27, 2025) quashed the FIR and consequential proceedings.

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ARCHANA ARORA 2025.09.03 17:18 I attest to the accuracy and integrity of this document

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CRM-M- 3900 of 2020 2

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entire sale consideration had been paid by the petitioner and all documents for transfer of ownership were executed in favour of the petitioner. A “No Dues Certificate/No Objection Certificate issued by the Punjab Gramin Bank had also been issued in favour of the petitioner regarding clearance of the loan availed by Munish Bahri against the said car. After purchase of the said car from first owner Munish Bahri, the petitioner had hypothecated the said car with HDFC Bank and cleared the loan on 28.02.2018 and the HDFC Bank had issued loan closure letter dated 21.03.2018 to the petitioner. Notwithstanding the same, the Manager, Punjab Gramin Bank, Waryana, Jalandhar gave a complaint for registration of FIR against Munish Bahri i.e. vendor of the petitioner alleging that Munish Bahri had availed Car Loan facility from Punjab Gramin Bank for purchase of the above said car but failed to repay the bank loan and had sold the car without intimation to the Bank.

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Learned counsel for the respondent-Bank on instructions from Ms. Deepshikha Saini, Manager Punjab Gramin Bank informs that the entire loan amount of the Punjab Gramin Bank stands settled and there is no outstanding amount against the petitioner. He further does not dispute that the Bank had no transaction with the petitioner herein.

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Taking into consideration that there is no pending dispute inter-se between the petitioner and the respondent-Bank and the entire loan amount of respondent No.2-Bank has already been settled, the continuation of the proceedings against the petitioner, who

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ARCHANA ARORA 2025.09.03 17:18 I attest to the accuracy and integrity of this document

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CRM-M- 3900 of 2020

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is a subsequent purchaser for consideration would be an abuse of the process of law.

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The present petition is allowed. The FIR No. 152 dated 25.05.2016 (Annexure P-1) under Sections 406, 420, 465, 468, 471 IPC registered at Police Station Navi Baradari, Jalandhar City, Police Commissionerate Jalandhar, Punjab along with all other consequential proceedings arising therefrom stands quashed.

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( VINOD S. BHARDWAJ) JUDGE

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August 27, 2025 archana Whether speaking/reasoned Yes/No Whether Reportable : Yes/No

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ARCHANA ARORA 2025.09.03 17:18 I attest to the accuracy and integrity of this document

Satinder Pal Singh v. State of Punjab and Anr.

Case brief

What is this about?

What did the court decide?

Satinder Pal Singh v. State of Punjab and Anr.

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

Parties & counsel

Coram

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