The Calcutta High Court has quashed criminal proceedings initiated against Maruti Suzuki India Limited and its Chief Executive Officer pursuant to a complaint alleging cheating and criminal conspiracy in relation to the sale of a Maruti Suzuki Celerio ZXI MT vehicle. The complaint, filed before the 19th Metropolitan Magistrate, Calcutta, arose from the purchaser’s assertion that the vehicle lacked an auto-return feature in its power steering system, which he claimed was misrepresented through advertising and constituted a manufacturing defect.
The petition for quashing was filed under Section 482 of the Code of Criminal Procedure, 1973, challenging the maintenance of proceedings in C.S. No. 37758 of 2024, which invoked Sections 120B, 418, and 420 of the Indian Penal Code. Justice Ajay Kumar Gupta delivered the judgment on September 2, 2026, after examining the averments in the complaint, the vehicle’s specifications, and the promotional material relied upon by the complainant.
The complainant had purchased the vehicle from Dewars Garage Limited, Kolkata, for ₹6,17,469 without undertaking a test drive. After approximately three months of use and over 5,000 kilometres of operation, he reported during the first service that the power steering did not return to the central position after a turn. The service centre reportedly attributed the behaviour to ‘new technology’ and the ‘new normal’. Subsequently, the complainant alleged an inherent manufacturing defect and claimed he had been induced to purchase the vehicle through misleading advertisements that suppressed material facts about the steering system’s functionality.
Maruti Suzuki maintained that the Celerio ZXI MT model was manufactured and delivered according to its specified technical parameters and did not include a ‘return assist’ feature in its electric power steering system. The company further stated that the vehicle had undergone three complimentary services during which no irregularity was recorded in the steering mechanism.
The High Court observed that the brochure referred to by the complainant described the vehicle solely as being equipped with ‘Electric Power Steering’. It contained no express or implied representation that the steering wheel would automatically return to the neutral position after a turn. The Court concluded that, on the face of the brochure, there was no basis to infer that the complainant had been induced to enter into the transaction through misrepresentation or suppression of material facts.
Justice Gupta emphasised that the offence of cheating under Section 420 of the Indian Penal Code necessitates proof of dishonest or fraudulent intention at the inception of the transaction. Mere dissatisfaction with a product’s performance, or a subsequent disagreement regarding its quality or features, does not amount to cheating unless such intent is established from the outset. In the present case, the complaint failed to disclose any circumstance from which fraudulent or dishonest intention at the time of sale could reasonably be deduced.
Similarly, the Court rejected the allegation of criminal conspiracy under Section 120B of the Indian Penal Code. It held that the mere inclusion of multiple parties—the manufacturer, its officials, and the dealer—as accused persons does not, by itself, give rise to an inference of conspiracy. The complaint lacked specific facts demonstrating an agreement among the accused to commit an illegal act or to employ illegal means to achieve a legal objective.
The Court further noted that the complainant had not availed himself of the opportunity to test drive the vehicle prior to purchase, which ordinarily allows a buyer to assess the handling and functional characteristics of a motor vehicle. The manufacturer and dealer had subsequently inspected the car and provided a technical explanation concerning the absence of the return assist feature, which was consistent with the vehicle’s design specifications.
Reiterating a well-settled principle, the High Court held that criminal law cannot be utilised as a substitute for civil or consumer remedies simply because a consumer is dissatisfied with a product. Appropriate redress for grievances relating to product quality, performance, or alleged defects lies in civil or consumer forums, not in criminal proceedings, absent evidence of fraudulent intent.
Accordingly, the Court allowed the petition and quashed the criminal proceedings pending before the Metropolitan Magistrate, holding that the complaint disclosed, at best, a consumer dispute and did not establish a prima facie case of cheating or criminal conspiracy under the Indian Penal Code.