Quashing Cross-FIRs in the Interest of Justice: The Supreme Court’s New Principle under Article 142

1. Introduction

In Ramesh Kumaran v. State Through the Inspector of Police (2025 INSC 405), the Supreme Court of India addressed the issue of cross First Information Reports (FIRs) stemming from a dispute between two practising lawyers in Kodaikanal. The dispute led to the registration of two FIRs with allegations and counter-allegations of assault and threats. During the course of the proceedings, the Court explored the possibility of an amicable settlement in light of the fact that both disputing parties were members of the legal fraternity. This Judgment clarifies the approach to quashing cross-FIRs under the Supreme Court’s constitutional powers set out in Article 142 of the Constitution of India.

The main parties to the litigation were:

• First Appellant (Ramesh Kumaran): A lawyer practising in Kodaikanal.
• Second Appellant: Father of the first appellant.
• Second Respondent: Another lawyer practising in Kodaikanal.
• State through the Inspector of Police: Representing law enforcement.

Both FIRs related to the same incident that occurred on December 18, 2017, and targeted each other with accusations varying from assault to criminal intimidation.

2. Summary of the Judgment

The Supreme Court ultimately quashed both FIR No.499 of 2017 (filed by the appellants against the second respondent and two others) and FIR No.500 of 2017 (filed by the second respondent against the appellants) under its extraordinary powers, citing that:

• The interests of justice warranted putting an end to the cross-proceedings, especially since both disputants were lawyers, and the controversies had been drawn out over several years.
• The second respondent expressed a desire to apologize unconditionally; the Court hoped for reciprocal amity from the first appellant to end the dispute.
• The Court was mindful that ongoing criminal proceedings would harm both parties’ professional lives and resolve nothing constructively.
• By exercising its power under Article 142 of the Constitution, the Court could deliver substantive justice and prevent further acrimony.

While the first appellant initially resisted a combined resolution, the Court noted that both sides needed closure. Ultimately, the Court showed leniency toward the first appellant for threatening conduct (threatening self-harm during the proceedings), accepting his written apology and undertaking, but also reminding the appellant of the seriousness of such actions.

3. Analysis

3.1 Precedents Cited

The Judgment illustrates how the Court referred to its own inherent and constitutional powers to achieve a just and equitable outcome. While the text of the decision does not reference specific earlier Supreme Court cases by name, it relies on the well-established principle that courts enjoy wide discretionary power to quash criminal proceedings in appropriate circumstances, particularly where additional litigation serves no meaningful purpose. The Court’s approach is akin to earlier landmark rulings related to Article 142 and procedural fairness, where courts prioritize the administration of justice over technical and procedural strictures.

Notably, the Court’s broad approach to quashing FIRs that arise out of the same incident or represent counterblasts is reflective of existing legal doctrines holding that two or more FIRs about the same incident should be handled sparingly, to avoid duplication of charges and conflicting conclusions. Furthermore, the Court noted the importance of reconciliation under its equitable jurisdiction in disputes involving professionals with ongoing practice in the same courts.

3.2 Legal Reasoning

In delivering this Judgment, the Supreme Court highlighted several crucial points:

1. Cross-FIR Dynamics. Because FIR No.499 and FIR No.500 arose from the same facts and circumstances, they constituted a textbook scenario of “cross-FIRs.” Courts have historically frowned upon continued parallel proceedings of cross-FIRs if they cause unnecessary duplication and complicate the search for truth.
2. Attempt at Amicable Settlement. The Court underscored its attempt to encourage settlement, particularly since the aggrieved parties were members of the same Bar. The second respondent readily tendered an unconditional apology, reflecting a genuine desire to move past the conflicts. The Court reasoned that continuing with the trial would pave the way for further animosity, hindering both parties’ professional prospects.
3. Power under Article 142 of the Constitution. While one party was reluctant, the Court exercised its authority under Article 142, which empowers it to pass such decrees or orders as are necessary for doing complete justice. Quashing both FIRs best served the interests of justice and peace.
4. Threat in Court and Apology. The first appellant threatened self-harm if the Court quashed the FIR he had filed. The Court took the view that such threats challenged the administration of justice and were contemptuous in nature. However, based on the first appellant’s subsequent written apology and undertaking, the Court chose to refrain from initiating contempt proceedings.
5. Professional Conduct Expectations. Both litigants, being officers of the court themselves, are expected to maintain higher ethical standards. The Court reiterated that members of the Bar should resolve professional differences with decorum and that repeated litigation disrupts the efficient function of justice.

3.3 Impact

By reaffirming its power to quash FIRs under Article 142 to prevent protracted litigation, the Court sends a clear signal that, in cases of cross-FIRs emerging from the same factual backdrop, it will go a long way to find comprehensive solutions—even if one party hesitates. Legal practitioners must be aware that:

• Courts may choose the path of reconciliation, especially where disputes can be classified as personal or originating from professional animosity.
• Threatening statements, even if made under emotional distress, can be considered contemptuous, and lawyers in particular may face serious consequences if they fail to uphold appropriate courtroom conduct.
• Emphasis is placed on the principle of “substantial justice” over procedural hurdles or the parties’ short-term reluctance.

With both FIRs quashed, the parties are free to refocus on their professional responsibilities without the specter of prolonged criminal proceedings.

4. Complex Concepts Simplified

Cross-FIRs: These are essentially two separate FIRs registered by opposing parties about the same incident, each claiming to be the victim. When the courts are faced with such counter-allegations, they carry out a careful scrutiny to determine whether continuing both sets of proceedings is warranted or potentially duplicative and oppressive.

Article 142 of the Constitution of India: This provision grants the Supreme Court the authority to “pass such decree or make such order as is necessary for doing complete justice” in any case before it. It is an extraordinary power which the Court sometimes uses to quash criminal proceedings if it views them as contentious, vexatious, or harmful to the wider cause of justice.

Contempt of Court: Actions, including verbal threats or disrespectful conduct in open court, that undermine the authority or dignity of the court can amount to contempt. Such behavior is taken seriously because it has the potential to impair the proper administration of justice.

5. Conclusion

The Judgment in Ramesh Kumaran v. State Through the Inspector of Police (2025 INSC 405) illustrates the Supreme Court’s commitment to substantive justice and its willingness to end disputes that serve little purpose in the larger judicial framework. By quashing both FIRs under Article 142, the Court showcased how mutual settlement and an overarching view of justice can prevail over technical insistence, especially when both litigants are from the legal profession and stand to benefit from a cessation of protracted litigation.

The Court’s ruling emphasizes professional decorum and the principle that members of the Bar should use legal avenues responsibly. Ultimately, beyond just resolving a dispute between two individuals, the Court’s approach reinforces the notion that the highest judicial body stands ready to intervene decisively for the sake of justice, harmony, and professional solidarity.