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S.P Chengalvaraya Naidu vs Jagannath on 27 October, 1993

(ii) The second ground to hold that the registration of the FIR by the respondent no.2 was gross abuse of the processes of law and that the respondent no. 2 had not come to the Court with clean hands and suppressed the material facts. The Supreme Court in S.P. Chengalvaraya Naidu Vs. Jagannath 1994 AIR 853, though in a different context has clearly laid down that a fraud which is played by a party by withholding the documents or the material information of which he is in possession will vitiate the entire proceedings. The same principle has to be applied to a criminal proceeding especially in a criminal complaint which a party sets into the motion for the purpose of seeking redressal of his grievance. The Supreme Court in number of cases has laid down that purity of justice must be maintained at all cost. One of the facets of maintaining the purity of scheme of justice is that the party who invokes the jurisdiction of the Court must come with clean hands and should not suppress the material facts. Crl.M.C.Nos. 5133, 5135, 5381, 5382 & 5387/05 Page 23 of 29 In the instant case, as has been noted above, the petitioners had suppressed the material fact of putting the criminal justice machinery into motion firstly by filing a complaint in Karkardooma Courts and failed to obtain the requisite order regarding the registration of FIR under Section 156(3) Cr.P.C. and chose to file a fresh complaint before the learned Magistrate at Patiala House Court in a different forum without disclosing this fact, yet getting a direction to the police under Section 156 (3) Cr.P.C. to register an FIR on the basis of the same facts. This was purely possible on account of the concealment of the fact and therefore, in my considered opinion constitutes concealment of material facts as well as invoking the jurisdiction of the Court with unclean hands and the necessary consequence of this would be that this Court must quash the direction passed by the learned Magistrate directing the registration of the FIR and the FIR itself as it was obtained by a gross abuse of the processes of law.
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