Criminal Law

Family Member Protection: No Criminal Charges for Property Purchase from Accused

Case: G. Prasad Raghavan vs. Union Territory of Puducherry Date: October 10, 2025 Citation: 2025 INSC 1221

⚠️ DISCLAIMER: This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

❓ Question

If a family member is accused of cheating someone in a property deal, can you, as another family member, be criminally charged simply for later buying that property from them, even if you were not involved in the original cheating?

✅ Answer

No, you cannot be charged merely for being a subsequent buyer.

The Supreme Court has ruled that to be charged with a criminal offence like cheating, the prosecution must show your direct and personal involvement in the fraudulent act from the beginning.

Mere purchase of a property from an accused person, without any evidence that you shared their criminal intent or participated in their deception, is not a crime. Your status as a family member, by itself, does not make you a co-conspirator.

⚖️ Understanding the Legal Principles

[1] Criminal Liability is Personal and Requires Direct Involvement

The Court reinforced a fundamental principle of criminal law: guilt is personal. For someone to be convicted of a crime, it must be proven that they personally committed the acts that constitute the offence.

  • The Legal Test: The Court asked: "Did this person, through their own actions, fulfill the ingredients of the crime?" For the son, the answer was a clear no.
  • In This Case: The original transaction and all alleged false representations were made by the father (Accused No. 1) in 2015-2016. The son (the appellant) was a minor at that time and was not alleged to have made any promises, received any money, or induced the complainant in any way.

[2] The "Ingredients of the Offence" Must Be Strictly Proved

The Court performed a meticulous check of the essential elements required to prove the alleged crimes, particularly Cheating (Section 420 IPC) and Criminal Breach of Trust (Section 406 IPC).

  • Cheating (Section 420 IPC) Requires:
    1. Fraudulent or Dishonest Inducement: Deceiving a person.
    2. Delivery of Property: That person must deliver any property or alter a valuable security based on that deception.
  • Application: The son did not induce the complainant. The complainant was induced by the father years before the son entered the picture. Therefore, the essential ingredient of "inducement by the accused" was completely absent in the son's case.

[3] A Subsequent Legal Transaction Cannot Retroactively Create Criminality

This is a crucial takeaway for anyone buying property from family or others.

  • The Allegation: The prosecution's main argument was that the son, a student with no income, bought the property from his accused father in 2022. They implied this was proof of his involvement.
  • The Court's Rejection: The Supreme Court held that a later, legally registered transaction (a sale deed) cannot be used to impute criminal intent for a fraud that occurred years earlier. The son's purchase might be questionable from a financial standpoint, but without evidence of a prior conspiracy, it does not constitute the actus reus (guilty act) of cheating.
  • Key Distinction: A transaction that seems suspicious is not automatically a crime. The prosecution must bridge the gap with evidence of a common criminal intent at the time of the original offence.

[4] The Discharge Stage is a Vital Safeguard Against Baseless Prosecution

The Court highlighted the importance of the discharge process under Section 239 of the Code of Criminal Procedure (CrPC). At this stage, the judge must determine if there is enough evidence to even proceed to a full trial.

  • The Standard: The question is not whether the accused is guilty, but whether the accusations, even if taken at face value, disclose a crime for which the accused can be legally tried.
  • In This Case: The Court found that even if all the allegations in the chargesheet were accepted as true, they did not legally connect the son to the crimes of cheating or criminal breach of trust. Sending him to trial in such a scenario would be an abuse of process.

🧭 Your Action Plan: Navigating False or Misguided Criminal Charges

👤 If You Are Falsely Implicated as a Co-accused

1

Isolate Your Actions from the Main Accused's Actions

Create a clear, date-wise chart showing your complete absence from the original incident. Highlight that you were a minor, not present, or had no connection to the key events.

Demand Specifics: Insist that the prosecution clearly state your individual role in the crime. Vague allegations like "he is the son" or "he benefited later" are legally insufficient.

2

Challenge the "Ingredients of the Offence"

Break Down the Crime: Understand the essential elements of the offence you are charged with (e.g., for cheating: deception, inducement, wrongful gain/loss).

Match Facts to Law: Argue point-by-point how your actions do not satisfy any of these essential ingredients. For instance, "I never made any false promise to the complainant."

3

File for Discharge at the Earliest Stage

Do Not Wait for Trial: Use the discharge application (under Section 239 CrPC) as a shield to prevent a long and harrowing trial.

Argue Legal Insufficiency: Your argument should be that even if the prosecution's story is 100% true, it does not legally constitute an offence against you. This is a legal argument, not a factual dispute.

🏛️ If You Are the Investigating Agency (The Prosecution)

1

Establish a Direct and Causal Link

Go Beyond Suspicion: Do not charge someone based merely on their relationship to the main accused or because they benefited indirectly. You must find positive evidence of their active participation in the criminal plan.

Look for Evidence of Conspiracy: For a subsequent buyer to be charged, you need evidence—such as messages, emails, or witness statements—that shows they knew about the original fraud and the purchase was part of the plan to launder the proceeds.

2

Apply the "Ingredients Test" Before Filing a Chargesheet

Internal Scrutiny: Before naming someone as an accused, apply the same test the court would: Do the collected facts fulfill all the legal ingredients of the offence against this specific person? If not, do not charge them.

📘 Key Legal Provisions Explained

🏛️ Indian Penal Code, 1860 (IPC)

  • Section 415 - Cheating: Whoever, by deceiving any person, fraudulently or dishonestly induces the person so deceived to deliver any property to any person, or to consent that any person shall retain any property, is said to "cheat".
  • Section 420 - Cheating and Dishonestly Inducing Delivery of Property: This is the aggravated form of cheating, punishable with imprisonment.
  • Section 406 - Criminal Breach of Trust: Whoever, being entrusted with property or having dominion over it, dishonestly misappropriates or converts it to their own use, is guilty of criminal breach of trust.
  • Section 34 - Acts Done by Several Persons in Furtherance of Common Intention: When a criminal act is done by several persons in furtherance of the common intention of all, each of such persons is liable for that act as if it were done by him alone.

🏛️ Code of Criminal Procedure, 1973 (CrPC)

  • Section 239 - Discharge: If, upon considering the police report and the documents sent with it, and after hearing the accused and the prosecution, the Magistrate considers that the charge against the accused is groundless, the Magistrate shall discharge the accused.

🧠 Core Takeaway from the Supreme Court

"Mere purchase of a property from an accused, without evidence of a prior common intention to cheat, does not transform a subsequent buyer into a co-accused in the crime of cheating."

This judgment acts as a strong safeguard for individual liberty against guilt by association. It reminds the justice system that criminal law is not a tool to harass family members of an accused or to punish people for transactions that are merely suspicious but not illegal.

The line between civil wrongs (like a questionable transaction) and criminal offences (which require malicious intent and a guilty act) must be strictly maintained.

For the common citizen, it provides clarity and protection from being dragged into criminal cases where they had no real involvement.

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