In this Supreme Court case, the State of Odisha appealed against a High Court judgment that quashed charges against Nirjharini Patnaik and another individual. The case involved allegations of a conspiracy to forge documents facilitating the illegal transfer of government land. The State argued that the High Court failed to recognize the gravity of the offenses and overlooked evidence indicating the respondents’ involvement.

The Supreme Court found merit in the State’s argument, highlighting the respondents’ roles in manipulating documents and transactions related to the land. It emphasized the deliberate undervaluation of the land and involvement of key individuals in the real estate sector. The Court stated that dismissing the case prematurely could harm ongoing investigations and ordered the trial to proceed against the respondents.

Ultimately, the Supreme Court allowed the appeal, setting aside the High Court’s decision and directing the trial court to proceed with the case promptly.


Sanjiv Narang Adv. is an Advocate on Record in the Supreme Court of India. His qualifications include an LLB from University of Delhi and a Masters degree in Personnel Management from Panjab University,Chandigarh.In his more than 3 decades of experience, he has practiced law at the District, High Court and Supreme Court levels.He also has more than a decade of experience in the field of Management. He is the author of two books namely Laws for Women in India and Innovation, Why What and How.