The High Court reaffirmed that when dismissing a criminal quashing petition, referring to the reasoning and order in an identical matter heard and decided the same day is valid. This approach applies the existing legal position and does not create new law, but stands as a binding precedent within the court’s territorial jurisdiction for future cases involving similar facts and questions of law.
Summary
| Category | Data |
|---|---|
| Case Name | CRM-M/47337/2025 of SUKHDEV SINGH Vs STATE OF PUNJAB |
| CNR | PHHC011360542025 |
| Date of Registration | 26-08-2025 |
| Decision Date | 01-09-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | MR. JUSTICE SUMEET GOEL |
| Court | High Court of Punjab and Haryana |
| Precedent Value | Binding within the Punjab and Haryana High Court’s jurisdiction |
| Overrules / Affirms | Affirms existing practice of relying on analogous decisions on the same questions of law |
| Type of Law | Criminal Law—Quashing of FIR under Section 482 CrPC |
| Questions of Law | Whether a quashing petition may be dismissed by expressly referring to the reasoning and order passed in an identical matter heard and decided on the same day. |
| Ratio Decidendi |
The court held that where petitions raise identical questions of fact and law as those already decided on the same day by the same bench, direct reference to and reliance upon the previous order is permissible and appropriate. This avoids repetition in reasoning and upholds consistency in judicial pronouncements. Such dismissal does not introduce new law but confirms the established approach regarding the exercise of inherent jurisdiction under Section 482 CrPC. The practice supports judicial economy and fosters certainty, ensuring that similarly situated cases are treated alike. |
| Judgments Relied Upon | Order of the same date in CRM-M-477284-2025—Jogga Singh vs State of Punjab |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within Punjab and Haryana |
| Persuasive For | Other High Courts and benches addressing procedural approach in identical quashing petitions |
| Follows | Order in CRM-M-477284-2025—Jogga Singh vs State of Punjab |
What’s New / What Lawyers Should Note
- Confirms that a High Court may dismiss a quashing petition by referring to the detailed reasoning in an identical petition decided the same day.
- Clarifies that no separate, repetitive reasoning is necessary where questions of law and fact are identical.
- Reinforces that judicial consistency and economy are essential values in exercising the court’s inherent powers.
- Lawyers should be aware that their petitions may be decided with reference to contemporaneous decisions if the factual and legal matrix overlaps.
Summary of Legal Reasoning
- The court noted that the current petition raised identical facts and questions of law as a previous petition (CRM-M-477284-2025—Jogga Singh vs State of Punjab) decided on the same date by the same bench.
- It held that, to avoid unnecessary repetition of reasoning, it is permissible and appropriate to dispose of the current petition by adopting and referring to the order and reasons recorded in the prior case.
- The judgment affirms the principle of judicial economy and the desirability of consistent outcomes in matters with akin factual and legal circumstances.
- The court thus dismissed the petition by direct reference to the reasons set forth in its order in the Jogga Singh case.
Arguments by the Parties
Petitioner
Arguments not separately recorded in this order; treated as identical to those raised in CRM-M-477284-2025 (Jogga Singh v. State of Punjab), which addressed the same factual and legal issues.
Respondent (State of Punjab)
Arguments not separately recorded in this order; considered as addressed in the identically situated prior case.
Complainant
Arguments not separately recorded; treated as per analogous previous order.
Factual Background
The petition concerned a criminal quashing matter under Section 482 CrPC. The facts and legal issues presented were identical to those already adjudicated by the same bench on the same day in CRM-M-477284-2025 (Jogga Singh v. State of Punjab). The present petition was therefore dismissed referencing the reasoning and outcome of the prior order.
Statutory Analysis
- Section 482 of the Criminal Procedure Code (CrPC) was the central statutory provision considered.
- The court did not undertake a fresh detailed statutory interpretation but affirmed the established approach to inherent powers, as elucidated in a contemporaneous case involving identical facts and law.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions are recorded in the judgment.
Procedural Innovations
- The court endorsed the procedural step of disposing of a petition by expressly referring to the reasoning and order passed in an identical matter heard and decided by the same judge on the same date.
- This facilitates judicial clarity and streamlines the disposal of repetitive cases.
Alert Indicators
- ✔ Precedent Followed – The judgment applies and reaffirms existing procedural law regarding the treatment of identical petitions.
Citations
- CRM-M/47337/2025 of Sukhdev Singh vs State of Punjab (CNR: PHHC011360542025; Decision Date: 01-09-2025)
- CRM-M-477284-2025—Jogga Singh vs State of Punjab (order relied upon; cited in judgment)