26 Jun 2026 05:15 AM
Supreme Court
Supreme Court

Criminal Law -- Material Improvements in Subsequent Complaint -- Warrants quashing of criminal proceedings

Code of Criminal Procedure, 1973, S.482 -- Criminal Law -- Material Improvements in Subsequent Complaint -- Addition of grave allegations, absent in an earlier complaint, to a subsequent FIR constitutes a material improvement that cannot be ignored when examining abuse of criminal process. Where delay in lodging the FIR is coupled with such improvements, the proceedings warrant quashing. Suppression of an earlier complaint and subsequent introduction of new allegations supports an inference that criminal proceedings are an afterthought to a civil dispute.

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