Lok Adalat Compromise Cannot Be Treated as Admission of Guilt for Police Recruitment, Supreme Court Holds
A bench of Justices Manoj Misra and Manmohan restores a constable candidate's appointment, ruling that a Lok Adalat settlement in a cheating case cannot ground an adverse character finding.
The Supreme Court has set aside the cancellation of a provisional selection for the post of Stipendiary Cadet Trainee Police Constable (SCTPC) in Telangana, holding that a compromise before a Lok Adalat in a cheating case cannot be read as an admission of guilt, and that indictment in a police report alone — where the complainant herself chose not to pursue the matter — cannot justify an adverse character finding. The judgment, delivered on 21 May 2026 by a bench of Justice Manoj Misra and Justice Manmohan in Gajula Thirupathi v. The Telangana State Level Police Recruitment Board and Others (Civil Appeal No. 8059 of 2026, arising out of SLP (C) No. 018626/2026), restores the order of the Telangana High Court's single judge and overturns the Division Bench's reversal of that order.
How the Dispute Reached the Supreme Court
Gajula Thirupathi was provisionally selected for the SCTPC post subject to antecedent verification. In his application form, he disclosed Crime No. 190/2014, registered against him under Sections 417, 420 and 506 read with Section 34 of the Indian Penal Code, 1860. The case arose from a complaint by a neighbour with whom he had been in a relationship for about four years. She alleged that he had promised to marry her, later married another woman, and that his parents had threatened her. A charge sheet was filed on 30 December 2014. While the case was pending trial, both parties settled the matter before the Lok Adalat at JFCM Court, Peddapalli on 31 May 2015, compounding the offence under Section 320(8) of the Code of Criminal Procedure, 1973.
The Telangana State Level Police Recruitment Board issued a show cause notice and, rejecting the appellant's explanation, cancelled his provisional selection on 17 August 2020. The appellant challenged this before the Telangana High Court. A single judge allowed the writ petition on 20 November 2020, directing the respondents to reconsider the case in light of this Court's judgment in Avtar Singh v. Union of India, (2016) 8 SCC 471.
On reconsideration, the Board again cancelled the provisional selection on 29 January 2021. It reasoned that the offence was one of moral turpitude, that the victim may have settled for reasons other than the appellant's innocence, and that a compromise does not wash off criminal antecedents. The Board also relied on paragraphs from Avtar Singh and on Commissioner of Police v. Mehar Singh, (2013) 7 SCC 685.
The appellant challenged the second cancellation before the single judge again (W.P. No. 20833 of 2021). The single judge allowed the writ petition on 3 June 2024, directing the respondents to reconsider the case and, if the appellant had a clean record otherwise, to send him for training with the next batch of constables. The respondents filed an intra-court appeal (W.A. No. 1274/2024). The Division Bench allowed that appeal on 22 November 2024, holding that the compounding of the offence did not amount to a clean acquittal, that the employer is the best judge of suitability for a disciplined force, and that the single judge ought not to have interfered. The appellant then approached the Supreme Court.
What the Court Held
The Supreme Court allowed the appeal and restored the single judge's order. The Court held that the Screening Committee's decision to deny appointment was arbitrary. Two specific statements in the respondents' counter affidavit drew the Court's attention: first, that the compromise amounted to an admission of guilt; and second, that the appellant compromised because he was guilty. The Court found the first statement to be without any basis and the second to be “completely perverse and defies logic.”
The Court distinguished the facts from those in Mehar Singh, where the FIR alleged that the accused arrived armed with iron chains, lathis and stones, assaulted persons and broke bus windowpanes — a situation where the nature of the alleged conduct was independently observable and the compromise was with a bus owner rather than a complainant whose own testimony was indispensable to proving the charge. In the present case, the Court found that whether the prosecutrix was deceived into the relationship was something only she could establish. When she chose not to pursue the matter and consented to compound the case, there was no occasion for the respondents to draw an adverse inference about the appellant's character.
The Court's Reasoning on Cheating, Consent and Character
The Court's analysis turned on the nature of the offence alleged. Cheating under Section 417 IPC requires false representation or deception. The Court observed that whether a person was deceived into a relationship can ordinarily be determined only from the statement of the person allegedly deceived. Unless that person steps into the witness box, it cannot be said that deception occurred. The prosecutrix here led no evidence and consented to compound the case. In those circumstances, the Court said, there was no occasion to read between the lines and draw an adverse inference.
The Court also noted the undisputed facts: the appellant and the victim were adult neighbours who had known each other for about four years; the relationship was of a consensual nature between two adults; there was no indictment under Section 376 IPC; the threats alleged in the FIR were attributed to the appellant's parents, not to the appellant himself; and there was no material on record — not in the show cause notice, not in the cancellation order, and not in the counter affidavit — to suggest that the victim was pressured or allured into the compromise.
The Court set out the conditions under which an employer may legitimately deny appointment despite an acquittal or compounding. There must be material on record showing that an offence involving moral turpitude was indeed committed, and there must be material linking the candidate to that offence even though he may have earned an acquittal through a technical latch, benefit of doubt, or witnesses turning hostile. Where those conditions are not met, a decision to deny appointment on the basis of antecedents will be arbitrary.
The Court also referred to its earlier judgment in Ravindra Kumar v. State of Uttar Pradesh and Others, (2024) 5 SCC 264, which identified a range of aspects relevant to testing the validity of a cancellation order based on past criminal antecedents: the nature of the office, the timing and nature of the criminal case, the overall consideration of the acquittal judgment, the nature of the query in the application form, the contents of character verification reports, the socio-economic background of the applicant, other antecedents of the candidate, and the contents of the cancellation order itself.
Applying those considerations, the Court found that the appellant had made a full and truthful disclosure; that the criminal case did not go to trial; that the victim herself withdrew the allegations; that there was no other adverse material on record; and that the police verification certificate showed a clean record except for the one case. In those circumstances, the decision to deny appointment could not be sustained.
The Court also made a broader observation about pre-marital relationships. It noted that physical relationships between two consenting unmarried adults cannot and should not by themselves be a ground to draw an adverse impression about character, and that where such a relationship spans several years, there is a presumption of valid consent. The Court cited Sonu @ Subash Kumar v. State of Uttar Pradesh, (2021) 18 SCC 517; Deepak Gulati v. State of Haryana, (2013) 7 SCC 675; and Ravish Singh Rana v. State of Uttarakhand and Another, 2025 SCC OnLine SC 1055, in support of that position.
Outcome
The Supreme Court allowed Civil Appeal No. 8059 of 2026. The impugned order of the Division Bench of the High Court for the State of Telangana at Hyderabad dated 22 November 2024 was set aside. The order of the learned single judge dated 3 June 2024 was restored, directing the respondents to reconsider the appellant's case and, if he has a clean record otherwise, to send him for training with the next batch of constables. There was no order as to costs. Pending applications, if any, were disposed of.