Source: Supreme Court  

Why in News? 

Recently, Justices Vikram Nath and Prasanna B Varale held that the existence of civil disputes does not justify quashing of criminal proceedings when a prima facie case of fraud and misappropriation is made out. 

• The Supreme Court held this in the matter of Kathyayini v. Sidharth P.S. Reddy & Ors. (2025). 

What was the Background of Kathyayini v. Sidharth P.S. Reddy & Ors., (2025) Case? 

• Kathyayini is the daughter of K.G. Yellappa Reddy and Jayalakshmi, who had eight children together - three sons (Sudhanva Reddy, Guruva Reddy, and Umedha Reddy) and five daughters (Lalitha, Jayashree, Rita, Bhavani, and Kathyayini). The respondents Sidharth P.S. Reddy and Vikram P.S. Reddy are sons of Sudhanva Reddy, making them Kathyayini's nephews. 
• Kathyayini's parents jointly purchased land measuring 19 guntas at Dodda Thogur, Bengaluru through a registered sale deed dated 17th February 1986. Her father K.G. Yellappa Reddy acquired this property using proceeds from the sale of certain ancestral properties. Both parents have since passed away. 
• The Bengaluru Metro Rail Corporation Limited acquired the family land, awarding total compensation of Rs. 33 crores. Kathyayini believed this substantial amount would be distributed equitably among all eight children of her parents. 
• Kathyayini discovered that her elder brother Sudhanva Reddy and his sons (the respondents) had allegedly orchestrated a criminal conspiracy to deprive her and her sisters of their rightful shares. The alleged fraudulent scheme involved: 
• Creating a fabricated family tree dated 18th January 2011 by allegedly bribing village accountant Narasimhaiah. This document showed only the three sons as heirs, completely excluding all five daughters. 
• Preparing an allegedly fake partition deed dated 24th March 2005, dividing the land only among the male heirs - Sidharth P.S. Reddy, Vikram P.S. Reddy, Guruva Reddy, and Umedha Reddy. 
• Based on these allegedly forged documents, the brothers claimed and received Rs. 1.80 crores from the Metro compensation. Subsequently, a total of Rs. 27 crores was released and credited to accounts of Sidharth P.S. Reddy, Vikram P.S. Reddy, Umedha Reddy, and Ashok Reddy. 
• The fraud came to light when Sudhanva Reddy, in a dispute with his son Prajwal Reddy (from his second wife), revealed the truth about the fabricated partition deed. He wrote to the Managing Director of Bengaluru Metro Rail Corporation stating that the partition deed was fabricated by his brothers and sons. This led to KIADB stopping further payments and depositing Rs. 5.59 crores with the trial court. 
• Upon learning of the fraud on 6th October 2017, Kathyayini confronted her brothers, who allegedly threatened to eliminate her. She filed complaints on 14th November 2017 and 20th November 2017 (jointly with sister Jayashree), leading to FIRs being registered against the accused parties. 
• Kathyayini and her sister Jayashree filed civil suits seeking partition of family properties, equal share in compensation, and declaration that the 2005 partition deed is void. Another civil suit was filed seeking an injunction against withdrawal of compensation amounts from bank accounts. 

What were the Court’s Observations? 

• The Supreme Court observed that a prima facie case for criminal conspiracy and cheating exists against the respondents. The court noted that they, along with their uncles, attempted to defraud their aunts by creating forged documents with the motive to gain the entire monetary award while bypassing the appellant and her sisters. 
• The Supreme Court found that the Karnataka High Court erroneously relied upon the Sub-Registrar's statement regarding the genuineness of the partition deed dated 24th March 2005. The court emphasized that this statement had not been subjected to cross-examination, making it unwise to rely on unverified testimony to ascertain the document's genuineness. 
• The court observed that the High Court could not find justification to deny that respondents misrepresented the family tree. The court acknowledged that respondents were bound to disclose the names of all daughters of K.G. Yellappa Reddy and Jayalakshmi in the family tree, and considering that both documents were used to gain monetary compensation, their genuineness must be put to trial. 
• The Supreme Court held that no bar exists against prosecution if offences punishable under criminal law are made out against parties to a civil suit. The court emphasized that criminal law and civil law can run side by side, as the two remedies are not mutually exclusive but coextensive, differing in their content and consequence. 
• The court reiterated that criminal law aims to punish offenders who commit offences against persons, property, or the State, while civil remedies address wrongdoing through different mechanisms. The pendency of civil proceedings on the same subject matter involving the same parties provides no justification to quash criminal proceedings if a prima facie case exists. 
• The court observed that the long chain of events - from creating a family tree excluding daughters, preparing a partition deed among only sons and grandsons, and distributing compensation among respondents - was sufficient to conclude active effort by respondents to reap benefits from the land in question. The alleged threats to the appellant and her sisters further affirmed the respondents' motive. 
• The Supreme Court concluded that all factors suggest a criminal trial is necessary to ensure justice to the appellant. The court emphasized that criminal proceedings must continue to their logical end when prima facie cases are established, regardless of parallel civil disputes. 

What is a Prima Facie Case ? 

• Definition and Concept of Prima Facie Case: 
  • A prima facie case refers to evidence that, on first appearance or on the face of it, establishes sufficient grounds to support a legal claim or charge. In criminal law, it means there exists sufficient evidence which, if unrebutted, would warrant a conviction.  
  • The term literally means "at first sight" or "on first appearance" and represents the minimum threshold of evidence required to proceed with criminal prosecution. 
• Standard for Establishing Prima Facie Case: 
  • Courts do not require proof beyond reasonable doubt at the prima facie stage. Instead, they examine whether there exists reasonable suspicion or probable cause to believe that an offence has been committed by the accused. 
  • The evidence need not be conclusive but must be sufficient to raise a reasonable presumption of guilt that warrants further investigation and trial. 

Why is it Crucial in Criminal Proceedings Despite Pending Civil Disputes? 

• Judicial Approach to Prima Facie Determination: 
  • Courts adopt a cautious approach when determining whether to quash criminal proceedings at the prima facie stage.  
  • They recognize that premature termination of criminal cases can deny justice to victims and undermine the rule of law.
• Burden of Proof at Prima Facie Stage: 
  • At the prima facie stage, the prosecution need not prove guilt beyond reasonable doubt. Instead, they must demonstrate reasonable grounds for suspicion that the accused committed the alleged offences.  
  • This lower threshold ensures that meritorious cases proceed to trial where evidence can be properly examined.
• Protection Against Abuse of Process: 
  • While courts protect against frivolous or malicious prosecutions, they also safeguard against premature dismissal of cases that merit full investigation. 
  • The prima facie standard strikes a balance between protecting accused persons from harassment and ensuring that genuine cases receive proper adjudication. 
• Implications for Case Management: 
  • The principle of continuing criminal proceedings despite civil disputes has significant implications for case management and judicial efficiency. 
  • It prevents accused persons from using civil litigation as a shield to escape criminal liability.
• Prevention of Forum Shopping: 
  • This principle prevents parties from manipulating the legal system by filing civil suits to create grounds for quashing criminal proceedings. 
  • It maintains the integrity of both civil and criminal justice systems by ensuring they operate independently.
• Ensuring Comprehensive Justice: 
  • By allowing concurrent proceedings, the legal system ensures that all aspects of wrongdoing are addressed appropriately.  
  • Victims receive both criminal justice through punishment of offenders and civil justice through compensation for damages. 

Case Laws

• K. Jagadish v. Udaya Kumar G.S. and Another (2020): 
  • The Supreme Court relied on this precedent which established that the same set of facts may give rise to both civil and criminal remedies, and availing civil remedy does not preclude criminal proceedings.
• Pratibha Rani v. Suraj Kumar and Another (1985): 
  • This case established that criminal law and civil law can run side by side as the two remedies are not mutually exclusive but coextensive, differing in their content and consequence.
• Kamaladevi Agarwal v. State of W.B. and Others (2001): 
  • This precedent reinforced that pendency of civil proceedings cannot be grounds for quashing criminal proceedings, and criminal cases must proceed according to prescribed procedures under the Code of Criminal Procedure.