Sunisha Anand v. State of Haryana 2026 INSC 494 - FIR Quashing - Civil Dispute

Extracted Case Information

Case name: Sunisha Anand v. State of Haryana & Anr.Neutral citation: 2026 INSC 494Coram: Hon’ble Mr. Justice Sanjay Kumar and Hon’ble Mr. Justice K. Vinod ChandranJudgment date: 11 May 2026Court / Jurisdiction: Supreme Court of India, Criminal Appellate JurisdictionCase number: Criminal Appeal No. 2457 of 2026

Caselaws and Citations Referred

1. Mariam Fasihuddin & Anr. v. State by Adugodi Police Station & Anr., (2024) 11 SCC 733
2. • Cited by the appellant to contend that a supplementary report/FIR without new evidence is impermissible or should be frowned upon.

Statutes / Laws Referred or Implicated

The order does not name specific statutory provisions, but from the facts and context the following legal areas are clearly engaged:

• Criminal law relating to:
• • Forgery and use of forged documents (Indian Penal Code provisions on forged GPAs and fraudulent transfer of property).
  • Cheating / criminal breach of trust concepts (allegations of fraudulent conveyance of land).
• Principles governing:
• • When criminal proceedings can be quashed in matters that are essentially civil in nature (inherent powers / supervisory jurisdiction, though the exact provision such as section 482 CrPC is not expressly mentioned in the text).
• Land and property law concepts:
• • Transfer of land and title, including where part of the land has been transferred to the State (here, State of Uttar Pradesh).
  • Effect of executing General Power of Attorney and sale deeds based on such GPA.
  • Reference to “jamabandi” (record-of-rights entry) in sale documentation.

Because this is a brief “Order” format, the Court speaks in principle without listing individual sections of IPC or CrPC, but the reasoning is grounded in the boundary between civil disputes and criminal prosecution in land/forgery contexts.

Three-Sentence Brief Summary

The Supreme Court considered a challenge by Sunisha Anand to an FIR in which she was added later as an accused in a land dispute where allegedly fake General Power of Attorneys had been used to transfer property, even though part of that land had already been transferred to the State of Uttar Pradesh. The Court found that the appellant and her mother themselves executed the GPAs, so they could not be called “fake” on that basis; further, any over‑conveyance of land or reference to a non‑existent jamabandi might give rise to a civil dispute or claims by purchasers, but did not disclose criminal liability against the appellant on the facts stated in the FIR. Holding that criminal law cannot be used to advance what is essentially a civil dispute—especially when a civil suit by the complainant is already pending—the Court quashed FIR No. 588 dated 02.06.2018 at Faridabad Central Police Station insofar as it concerned the appellant.