The Calcutta High Court has quashed criminal proceedings against Maruti Suzuki India Limited and its CEO over allegations that a Celerio ZXI MT purchased by a consumer did not have an auto-return feature in its power steering, holding that the complaint disclosed, at best, a consumer dispute and did not establish the ingredients of cheating or criminal conspiracy.

Justice Ajay Kumar Gupta, in a judgment delivered on September 2, 2026, observed that criminal law cannot be employed as a substitute for civil or consumer remedies merely because a purchaser is dissatisfied with the performance or features of a product.

The Court was hearing a petition under Section 482 of the Code of Criminal Procedure, 1973, seeking quashing of proceedings in C.S. No. 37758 of 2024, pending before the 19th Metropolitan Magistrate, Calcutta, under Sections 120B, 418 and 420 of the Indian Penal Code.

Consumer alleged steering defect and misleading representation

The complainant had purchased a Maruti Suzuki Celerio ZXI MT from Dewars Garage Limited, Kolkata, for ₹6,17,469. After taking delivery, he noticed that the power steering did not automatically return to the central position after a turn.

According to the complaint, the issue was raised during the first service after nearly three months of use and over 5,000 kilometres. The service centre allegedly dismissed the concern as a consequence of “new technology” and the “new normal.” The complainant subsequently alleged that the vehicle suffered from an inherent manufacturing defect and that he had been deceived through misleading advertisements.

The manufacturer, however, maintained that the vehicle was functioning according to its specifications and that the particular model did not have a “return assist” feature in its power steering. The company also pointed out that the vehicle had undergone three free services without any abnormality being recorded.

The complainant had also filed a consumer case before the District Consumer Disputes Redressal Commission, Kolkata-1 (North).

The High Court noted that the complainant had purchased the vehicle without a test drive and had used it extensively before raising the grievance. It observed that a test drive ordinarily allows a prospective purchaser to understand the handling and functional characteristics of a vehicle before committing to the purchase.

The Court further noted that the manufacturer and dealer had inspected the vehicle and furnished a technical explanation regarding the absence of the return assist feature.

Upon examining the brochure relied upon by the complainant, the Court found that it merely described the vehicle as being equipped with “Electric Power Steering.” There was no representation, express or implied, that the steering wheel would automatically return to its central position after negotiating a turn.

“Consequently, the allegation that the petitioners induced the complainant to purchase the vehicle by misleading advertisement or suppression of material facts does not find prima facie support from the brochure itself,” the Court held.

The Court reiterated that cheating under Section 420 IPC requires dishonest or fraudulent intention at the inception of the transaction. Mere failure of a product to satisfy a purchaser's expectations, or a subsequent dispute regarding its quality or performance, does not by itself constitute cheating unless the requisite mens rea is established from the beginning.

In the present case, the complaint did not disclose any circumstance from which fraudulent or dishonest intention at the time of sale could reasonably be inferred.

The Court also rejected the allegation of criminal conspiracy under Section 120B IPC, observing that the complaint merely arrayed the manufacturer, its officials and the dealer as accused persons.

“Criminal conspiracy cannot be inferred merely because more than one person is impleaded as an accused,” the Court observed, holding that the complaint did not disclose specific facts indicating an agreement or meeting of minds to commit an illegal act.

The Court further noted that the CEO/Managing Director had been arraigned without any specific allegation of participation in the sale transaction, interaction with the complainant or involvement in the alleged acts.

“Mere fact that a person occupies a high managerial position in a company cannot render him vicariously liable for alleged criminal acts of the company in the absence of a statutory provision creating such liability or specific allegations demonstrating his active participation,” the Court held.

The Court held that the dispute, as pleaded, essentially concerned the quality, features and performance of a consumer product. Whether the steering characteristics amounted to a manufacturing defect, whether the model lacked a particular feature, or whether the advertisements created any misunderstanding were matters ordinarily falling within consumer jurisprudence and contractual obligations.

Referring to the pending consumer case, the Court observed that the Consumer Protection Act provides an efficacious statutory mechanism for adjudicating disputes relating to alleged manufacturing defects, deficiency in service and unfair trade practices.

Relying on the Supreme Court's decision in Ford India Limited v. Sunbeam Ancillary Private Limited, the Court held that the essential ingredients of cheating were not made out and that continuation of the criminal proceedings would amount to an abuse of the process of law.

The High Court additionally found that the trial court had failed to consider the mandatory requirement under Section 202(1) CrPC before issuing summons, since the petitioners' official and residential addresses were outside the territorial jurisdiction of the court.

The Court held that this was an additional ground for quashing the proceedings.

Accordingly, the Court allowed the criminal revision petition and quashed the proceedings in C.S. No. 37758 of 2024, along with all orders passed therein, insofar as the petitioners were concerned.

Case: Maruti Suzuki India Limited & Anr. Versus Vijaynath Jha

Case No: C.R.R. No. 2314 of 2024

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