LALMUNI DEVI vs STATE OF BIHAR .

The Supreme Court held that a complaint alleging fraud in the execution of a gift deed can sustain both civil and criminal liability, as established under Sections 419, 420, 467, and 120B of the Indian Penal Code. The Court emphasized that the existence of a civil remedy does not preclude the maintenance of a criminal complaint. The Court set aside the High Court's order quashing the complaint, ruling that the allegations were sufficient to warrant criminal proceedings and did not constitute an abuse of process.