12. S. Anand v. State of Tamil Nadu & Anr.
2026 INSC 418
Forgery of Will – Purchaser under registered sale deed – Absence of material showing conspiracy – Criminal proceedings quashed against bona fide purchaser. [Indian Penal Code, 1860, S.420, 467, 468, 471, 120B; Code of Criminal Procedure, 1973, S.482]
FACTS
The complainant alleged that a forged will had been fabricated by the accused persons after the death of his father and that properties were sold based on such forged document.
An FIR was registered for offences relating to forgery, cheating and conspiracy. The investigating agency filed a charge sheet alleging that several accused persons had conspired to fabricate the will and utilise the same for the execution of sale deeds.
The appellant was one of the purchasers under the sale deed. He contended that he was a bona fide purchaser for value, had no role in the alleged fabrication of the will and had merely purchased the property after verifying title and possession.
The High Court refused to quash the proceedings under section 482 Cr.P.C. The appellant approached the Supreme Court.