Supreme Court Refuses Blanket Clarification on Civil Court Findings Impacting Criminal Cases: Mukesh Maganlal Doshi vs. State of Uttar Pradesh (2023)

Introduction

Date of the Judgment: April 26, 2023
Citation: 2023 INSC 437
Judges: Krishna Murari, J. and Ahsanuddin Amanullah, J.
Can a party who was not part of a previous Supreme Court case seek a clarification of the judgment by intervening in the case? The Supreme Court of India recently addressed this question, specifically regarding the impact of civil court findings on related criminal proceedings. The Court considered whether a blanket clarification could be issued to apply a previous judgment to a new party who was not originally part of the case. The bench comprised Justices Krishna Murari and Ahsanuddin Amanullah, who delivered a unanimous decision.

Case Background

The case involves a miscellaneous application by Mukesh Maganlal Doshi seeking clarification of a Supreme Court order dated 10.02.2020 in Criminal Appeal No. 249 of 2020. Doshi was not a party to the original appeal. The facts leading to the application are as follows:

On March 5, 2019, a complaint was filed with Mumbai police regarding the unauthorized sale of building units by business associates of the complainant. This included the sale of seven units to Doshi’s group. The complaint also alleged that these associates had fraudulently obtained loans from banks.

On March 19, 2020, the complainant approached the Central Bureau of Investigation (CBI) with the same grievances. While the police registered an FIR on September 23, 2020, against the business associates for fraudulent loan activities, the CBI did not register a complaint regarding the unauthorized sale of units.

Subsequently, a Commercial Suit No. (L) 370 of 2020 was filed by the complainant concerning the unauthorized sale of the seven units to Doshi’s group. This suit was resolved through a compromise, which was decreed by the High Court on March 16, 2021. The compromise acknowledged that Doshi’s group was a victim of fraud, and the disputed property or its value was returned to the complainant.

Following this, the Mumbai police filed a closure report under Section 157 of the Criminal Procedure Code, stating that no further investigation was needed regarding Doshi and his group.

However, Doshi’s group was implicated in proceedings under the Prevention of Money Laundering Act, 2002 (PMLA) against the complainant’s business associates. Doshi sought clarification of the Supreme Court’s 2020 order, which had held that a civil court’s findings could nullify the basis of a criminal complaint, to apply to his situation.

Timeline

Arguments

The applicant, Mukesh Maganlal Doshi, argued that the Supreme Court’s judgment dated 10.02.2020 in Criminal Appeal No. 249 of 2020 should be clarified to apply to his case. The core of his argument was:

• The judgment held that findings in civil proceedings can nullify the basis of a related criminal complaint.
• In his case, a civil suit regarding the unauthorized sale of units was resolved through a compromise decree, acknowledging his group as victims of fraud.
• Despite this, his group was implicated in PMLA proceedings against the business associates of the complainant.
• If the 2020 judgment is not clarified to apply to him, it would lead to a multiplicity of proceedings and cause injustice.
• Such a clarification would serve the ends of justice without causing prejudice to anyone.

Summary of Arguments

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame specific issues but addressed the core question of whether a clarification of its previous order could be granted to a party who was not part of the original proceedings. The court considered the applicant’s request for intervention and clarification of the order dated 10.02.2020.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following legal authority:

• Article 141 of the Constitution of India: This article states that the law declared by the Supreme Court shall be binding on all courts within the territory of India.

Authorities Considered by the Court

Judgment

The Supreme Court rejected the applicant’s request for clarification, stating that the applicability of the law laid down in the 2020 judgment must be determined based on the specific facts of each case by the concerned court where proceedings are pending.

The Court also considered the authorities as follows:

• The Court acknowledged that the law laid down by the Supreme Court is binding under Article 141 of the Constitution of India. However, it emphasized that the application of this law depends on the specific facts of each case.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the principle that the application of a legal precedent is fact-dependent. The court emphasized that while its judgments are binding, their applicability must be determined by the concerned court based on the specific facts of each case. The Court was not inclined to issue a blanket clarification that would apply to all cases without a proper factual assessment.

The Court’s reasoning was as follows:

The Court rejected the applicant’s request for a blanket clarification, emphasizing that the applicability of a Supreme Court judgment depends on the specific facts of each case. The court noted that while its judgments are binding under Article 141 of the Constitution of India, the concerned courts must determine their applicability based on the facts of the case. The Court stated, “It goes without saying that facts and circumstances of a particular case are required to be tested to find out whether the law declared by this Court is applicable to the said facts or not.”

The Court also observed, “We have no reason to doubt that the courts will not follow the binding law declared by this Court in case it is found that the same is applicable to the facts of a particular case.” The Court further clarified, “the applicant cannot be permitted to seek clarification of the order dated 10.02.2020 by way of an intervention as the same is a matter to be considered by the concerned court, where the proceedings in respect of the applicant is pending.”

Key Takeaways

• The Supreme Court will not issue blanket clarifications of its judgments to parties who were not part of the original proceedings.
• The applicability of a Supreme Court judgment depends on the specific facts of each case.
• Lower courts must determine the applicability of Supreme Court precedents based on the factual context of the cases before them.
• Parties seeking to apply a Supreme Court judgment to their case must argue its applicability before the concerned court, not through intervention in the original case.

Directions

The Supreme Court did not issue any specific directions in this case. The Court rejected the application for intervention and clarification.

Specific Amendments Analysis

Not Applicable

Development of Law

The ratio decidendi of this case is that a party cannot seek clarification of a Supreme Court judgment by way of intervention if they were not a party to the original case. The applicability of a Supreme Court judgment depends on the specific facts of each case and must be determined by the concerned court. There is no change in the previous position of law, rather the court has clarified the procedure to be followed.

Conclusion

The Supreme Court dismissed the miscellaneous application filed by Mukesh Maganlal Doshi, who sought clarification of a previous order by intervening in a case where he was not an original party. The Court reiterated that while its judgments are binding, their application is fact-dependent and must be determined by the relevant court. The Court refused to issue a blanket clarification, emphasizing that each case must be assessed based on its own merits and facts.