Syed Askari Hadi Ali Augustine ... vs State (Delhi Admn.) & Anr

The Supreme Court addressed the interplay between probate proceedings and criminal allegations of forgery concerning a Will, specifically under Sections 420, 468, and 34 IPC. The Court held that the pendency of probate proceedings does not preclude the initiation of criminal proceedings for forgery, establishing that both can coexist without one affecting the other. The appeal was allowed, affirming the High Court's decision to quash the Permanent Lok Adalat's order and emphasizing the need for civil adjudication of title disputes before mutation can be granted.