Introduction:

The case of Haji Iqbal @ Bala vs. State of Uttar Pradesh arose when the appellant challenged the Allahabad High Court’s refusal to quash an FIR filed against him under several sections of the Indian Penal Code (IPC). The dispute revolved around unpaid construction dues linked to Glocal University, founded by Haji Iqbal. The FIR, filed nearly two years after the alleged events, accused him of serious criminal acts such as dacoity and kidnapping. The Supreme Court was called upon to determine whether the FIR revealed any genuine criminal offense or if it was a misuse of legal machinery driven by political and personal vendetta.

Background:

• In 2012, Glocal University, associated with Haji Iqbal, awarded construction contracts worth approximately ₹5.34 crore to contractor Balraj Sethi for various projects including a school building, corporate office, and girls’ hostel.

• By 2015, construction was completed, but the contractor claimed ₹1.20 crore remained unpaid and alleged that building materials worth ₹1.86 crore were retained on campus.

• In March 2021, the contractor claimed he was threatened and unlawfully detained by Haji Iqbal and his family when he attempted to recover the dues.

• An FIR (No. 0007/2023) was filed on January 10, 2023, nearly two years after the alleged events, under IPC Sections 395 (dacoity), 386 (extortion), 365 (kidnapping), 342 (wrongful confinement), and 506 (criminal intimidation).

• Haji Iqbal contended that the allegations were false, politically motivated, and that a civil financial dispute had been deliberately misrepresented as a criminal case.

Key Developments:

• Allahabad High Court: Refused to quash the FIR, allowing the criminal investigation to proceed.

• Supreme Court Appeal: Haji Iqbal appealed, arguing the FIR was fabricated and filed with mala fide intent.

• Supreme Court Observations:

  • Found significant delay and lack of specific details in the FIR.

  • Noted that essential ingredients of the alleged crimes were missing even if the FIR was accepted as true.

  • Held that the dispute was civil in nature concerning unpaid construction dues.

  • Observed that the FIR appeared to be politically motivated, pointing to multiple similar cases against the appellant post-2017.

Issues:

Whether the allegations made in the FIR disclosed any cognizable criminal offenses warranting investigation and prosecution, or whether the FIR constituted an abuse of process that should be quashed under Section 482 CrPC and Article 226 of the Constitution.

Current Status (Judgment):

The Supreme Court allowed the appeal and quashed the FIR, holding that:

• The FIR was filed after an unexplained delay of nearly two years.

• The allegations did not establish prima facie evidence of kidnapping, intimidation, or dacoity.

• The matter was purely civil, arising from unpaid construction contracts.

• The FIR was a product of mala fide intent and political vendetta, constituting an abuse of criminal process.

• The case satisfied the quashing conditions laid down in State of Haryana v. Bhajan Lal (1992).

Accordingly, the Allahabad High Court’s order was set aside, and all related criminal proceedings were dismissed.

Conclusion:

The Supreme Court reaffirmed that criminal law cannot be used as a weapon for personal or political vengeance. The judgment underscores that civil disputes, particularly contractual or financial disagreements, must not be given criminal color. The Court’s decision serves as a safeguard against the misuse of criminal proceedings for harassment, emphasizing judicial responsibility to protect individuals from frivolous or malicious litigation.