Mr. Robert John D'Souza & Ors vs Mr. Stephen V. Gomes & Anr

The Supreme Court upheld the dismissal of the appellants' petition to quash the criminal complaint filed under Sections 406, 409, and 420 IPC, affirming that the complainant had locus standi despite not being a member of the Mukka Welfare Society. The Court found that the delay in filing the complaint did not negate the allegations of fraudulent usurpation of property by the appellants, who were in positions of authority within the Society. The Court concluded that the ingredients of the alleged offences were sufficiently established, thus allowing the criminal proceedings to continue.