SANJAY DUTT & ORS. versus THE STATE OF HARYANA & ANR.

SANJAY DUTT & ORS. versus THE STATE OF HARYANA & ANR.

The complaint and the order taking cognizance were quashed because the allegations against the individual appellants were vague and did not disclose personal conduct making them liable under Section 4 read with Section 19 of the Punjab Land Preservation Act, 1900; vicarious criminal liability cannot be imputed to directors/officers in the absence of a statutory provision and specific, substantiated allegations linking them to the offence.

Parties
Appellant Director; Managing Director and Chief Executive Officer of Tata Realty and Infrastructure Limited: Sanjay Dutt; Appellant General Manager (at Relevant Time); Currently Assistant Vice President of Tata Realty and Infrastructure Limited: Kamal Sehgal; Appellant Project Manager: Satpal Singh; Respondent: The State of Haryana & Anr.
Jurisdiction
India
Judgment Date
01 January 2025
Procedural Posture
Criminal Appeal / Final Judgment by the Supreme Court Allowing the Appeal and Quashing the Complaint and Order Taking Cognizance
Outcome
Appeal allowed.
Legal Topics
Vicarious Liability, Directors' Liability, Section 4 Punjab Land Preservation Act, 1900, Section 19 Punjab Land Preservation Act, Quashing of Complaint
Criminal Law Environmental Law Company Law Vicarious Liability Directors' Liability Section 4 Punjab Land Preservation Act, 1900 Section 19 Punjab Land Preservation Act, 1900 Quashing of Complaint

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Parties

Sanjay Dutt

Appellant Director; Managing Director and Chief Executive Officer of Tata Realty and Infrastructure Limited

Kamal Sehgal

Appellant General Manager (at Relevant Time); Currently Assistant Vice President of Tata Realty and Infrastructure Limited

Satpal Singh

Appellant Project Manager

The State of Haryana & Anr.

Respondent

Procedural Posture

Criminal Appeal / Final Judgment by the Supreme Court Allowing the Appeal and Quashing the Complaint and Order Taking Cognizance

Legal Issues

  1. 1 Whether vicarious liability can be attached to directors or office bearers of a company under the Punjab Land Preservation Act, 1900
  2. 2 Whether the complaint disclosed commission of an offence under Section 4 read with Section 19 of the Punjab Land Preservation Act, 1900
  3. 3 Whether the allegations in the complaint were sufficiently specific to fasten criminal liability on the individual appellants

Ratio Decidendi

The complaint and the order taking cognizance were quashed because the allegations against the individual appellants were vague and did not disclose personal conduct making them liable under Section 4 read with Section 19 of the Punjab Land Preservation Act, 1900; vicarious criminal liability cannot be imputed to directors/officers in the absence of a statutory provision and specific, substantiated allegations linking them to the offence.

Court Disposition

Appeal allowed.

Orders

  • Impugned complaint bearing CIS No.COMA-134-2024 and the order taking cognizance are quashed.
  • Pending applications, if any, stand disposed of.