Shailesh Kumar Singh alias Shailesh R. Singh vs. State of Uttar Pradesh (CRIMINAL APPEAL)

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I. Case Identification & Vitals

1. Court:
Supreme Court of India

2. Case Title:
Shailesh Kumar Singh alias Shailesh R. Singh vs. State of Uttar Pradesh & Ors.

3. Document Type and Date of Judgment:
Judgment, July 14, 2025

4. Case Number:
Criminal Appeal No. 2963 of 2025 (@ SLP (Crl.) No. 4880 of 2025)

5. SCR Citation:
NA

6. Neutral Citation:
2025 INSC 869

7. Disposal Nature:
Appeal Allowed

8. Case Type:
CRIMINAL APPEAL

9. Law Applicable:
Bharatiya Nyaya Sanhita, 2023; Criminal Procedure Code

10. Bench:

1. Hon’ble Justice J.B. Pardiwala
2. Hon’ble Justice R. Mahadevan

11. Judgment Authored by:
Hon’ble Justice J.B. Pardiwala*

II. Summaries & Core Issues

12. Headnote:
The Supreme Court quashed an FIR filed under Sections 60(b), 316(2), and 318(2) of the Bharatiya Nyaya Sanhita, 2023, against Shailesh Kumar Singh, co-founder of a film production company. The FIR was based on a commercial dispute regarding a failed business deal. The Court ruled that criminal law should not be used to settle civil disputes and criticized the High Court for directing mediation upon a monetary deposit without first evaluating the legality of the FIR. The Court held that no prima facie case of cheating or breach of trust was made out.

13. Short Summary:
The Supreme Court quashed the FIR against Shailesh Kumar Singh, finding the case to be a civil dispute mischaracterized as a criminal offence. The Court emphasized that criminal law must not be misused to recover money.

14. Issue for Consideration:
Whether the FIR disclosed any cognizable offence under BNS, 2023, or amounted to an abuse of process in a purely civil commercial dispute.

III. Procedural & Factual Background

15. Case Start Date:
January 9, 2025 (FIR Registration Date)

16. Case Arising From:
The FIR filed by Respondent No.4 alleged cheating and breach of trust in a business transaction. The High Court refused to quash the FIR and directed mediation on deposit of Rs. 25 lakhs.

17. Background and Facts:
The appellant is a co-founder of Karma Media and Entertainment LLP. Respondent No.4, operating Polaroid Media, accused him of misappropriating funds in an oral co-production deal. An FIR was filed under Sections 60(b), 316(2), and 318(2) BNS. The appellant sought quashing of the FIR on grounds of abuse of criminal process. The High Court instead ordered mediation conditioned on a Rs. 25 lakh deposit. The Supreme Court reviewed the FIR and found it disclosed no criminality.

18. Timeline:

• January 9, 2025: FIR registered
• March 7, 2025: High Court directed mediation
• July 14, 2025: Supreme Court quashed FIR

19. Parties Involved:

• Appellant: Shailesh Kumar Singh alias Shailesh R. Singh
• Respondent No.1: State of Uttar Pradesh
• Respondent No.4: Informant/Complainant (Representative of Polaroid Media)

20. Procedural History:

• High Court: Directed mediation with Rs. 25 lakh deposit
• Supreme Court: Quashed FIR, allowed appeal

IV. Legal Analysis & Arguments

21. Issues Framed:
Not Applicable

22. Areas of Debate:

1. Can a civil commercial dispute be prosecuted as a criminal offence?
2. Did the FIR disclose any intention to cheat from the inception of the agreement?

23. Cases Cited by Petitioner/Appellant:

• Delhi Race Club (1940) Ltd. vs. State of Uttar Pradesh, (2024) 10 SCC 690 – clarified criminal breach of trust and cheating
• Radheyshyam & Ors. vs. State of Rajasthan – referred by petitioner’s counsel

24. Cases Cited by Respondent/Defendant:
NA

25. Acts/Rules/Orders Referred:

1. Bharatiya Nyaya Sanhita, 2023
   • Section 60(b): Concealing design to commit offence
   • Section 316(2): Criminal breach of trust
   • Section 318(2): Cheating
2. Criminal Procedure Code

26. Acts/Rules/Orders Governing the Case: Bharatiya Nyaya Sanhita, 2023; CrPC

27. Literature Citation:
NA

28. Appearances for Parties:

• Appellant: Ms. Sana Raees Khan, Advocate
• Respondent No.4: Mr. Anand Mishra, Advocate
• State of U.P.: Mr. Shaurya Krishna, Advocate

29. Prayer: Quash the FIR registered under Sections 60(b), 316(2), and 318(2) of the BNS, 2023

30. Evidence & Findings:

1. Evidence: Oral agreement and monetary transfer
   • Finding: Insufficient to establish criminal intent or offence
2. Evidence: FIR and respondent’s claims
   • Finding: Lacked ingredients for cheating or breach of trust

31. Petitioner/Appellant Arguments:

1. FIR stems from a civil commercial dispute
2. No intention to cheat from inception
3. Mediation direction with monetary condition unjustified

32. Respondent/Defendant Arguments:

1. Alleged monetary loss from oral agreement
2. Claimed non-fulfilment of production obligations

V. Judgment & Conclusion

33. Ratio Decidendi:

1. Mere monetary disputes cannot be criminalized
2. Criminal law cannot be used to pressure recovery of dues in civil disputes
3. Courts must assess criminality before suggesting mediation

34. Final Decision: Appeal allowed. FIR dated January 9, 2025 quashed. Liberty granted to Respondent No.4 to seek civil remedies.

35. Legal Jargons and Maxims:

• Cheating: Deceiving someone fraudulently to cause wrongful gain
• Criminal Breach of Trust: Misappropriation of property entrusted lawfully
• Abuse of Process: Use of legal process for an ulterior or improper purpose

36. Exhibits:

• FIR copy
• Sections of Bharatiya Nyaya Sanhita
• Written submissions from both parties

VI. Key Learnings for Law Students and Legal Professionals

This judgment reaffirms that civil disputes should not be disguised as criminal cases. The High Court’s order directing mediation based on payment, without analyzing the criminality of the FIR, was improper. Legal practitioners must ensure that the criminal justice system is not misused for monetary recovery.

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