Andhra Pradesh HC Quashes FIR Against CM Chandrababu Naidu In Amaravati Land Pooling Case

The Andhra Pradesh High Court has quashed the FIR registered against Chief Minister N. Chandrababu Naidu and former Municipal Administration Minister P. Narayana in the Amaravati land pooling case, holding that the prosecution was vitiated by "deliberate political malice" and amounted to an abuse of the criminal process.

The Court held that the FIR sought to criminalise sovereign policy decisions taken in exercise of statutory powers and failed to disclose the commission of any cognizable offence.

Allowing two petitions filed under Section 482 CrPC, Justice Y. Lakshmana Rao quashed the 2021 FIR in its entirety against both petitioners.

The FIR had accused them of offences under various provisions of the IPC, the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act and the Andhra Pradesh Assigned Lands (Prohibition of Transfers) Act over the issuance of a Government Order relating to the Amaravati land pooling scheme.

The Court held that the FIR failed to disclose any cognizable offence against either Naidu or Narayana and instead attempted to convert official acts of governance into criminal offences.

It observed that the allegations essentially challenged policy decisions made while exercising sovereign rule-making powers under the APCRDA Act, which could not be subjected to criminal prosecution merely because a subsequent government disagreed with those decisions.

Holding that the case satisfied multiple categories laid down by the Supreme Court in State of Haryana v. Bhajan Lal for quashing criminal proceedings, the Court said the FIR did not disclose any cognizable offence, the allegations were "inherently improbable and constitutionally absurd," and there existed express statutory bars to prosecution under Section 146 of the APCRDA Act and Section 8 of the Assigned Lands Act.

It further found that the proceedings were "manifestly and demonstrably mala fide" and had been instituted with the "transparent ulterior motive of political persecution."

The 173-page judgment also noted that the complaint had been lodged by a political opponent rather than any allegedly aggrieved farmer.

The Court emphasised that even after nearly five years, not a single landowner had approached any forum alleging wrongful dispossession, a circumstance it found significant while assessing the bona fides of the prosecution.

Referring to earlier investigations into related allegations concerning Amaravati assigned lands, the Court noted that FIRs in Crime Nos. 14 and 15 of 2020 had, after investigation, been referred as "mistake of fact" by the CID, and those closure reports were accepted by the competent Special Court.

The allegations in those cases, the Court observed, were substantially similar to those made in the present FIR.

Summarising its conclusions, the Court observed: "The FIR is the product of deliberate political malice and represents a calculated campaign to delegitimize the acts of the previous Government. It was registered on the complaint of a political opponent, in the absence of any genuinely aggrieved person. It does not disclose any cognizable offence against either Petitioner in their individual capacities. It seeks to criminalize the sovereign exercise of rule-making power and delegated legislative authority".

It further noted that the FIR was barred by statutory immunity provisions, lacked specific allegations against either accused individually, and was preceded by a preliminary inquiry that itself disclosed no material warranting criminal investigation.

The Court therefore held that the FIR "does not stand on firm legal ground" and that it was "vitiated by mala fides and political vendetta." It accordingly quashed the proceedings in their entirety against both Naidu and Narayana.

In its concluding observations, the Court cautioned against the growing tendency to invoke criminal law against policy decisions following a change in government.

It observed that elected governments must remain free to take policy decisions, including controversial or even erroneous ones, without the constant threat of criminal prosecution whenever political power changes hands.

The Court also remarked that the repeated registration of criminal cases against political opponents had become a disturbing feature of Indian politics and expressed concern over the "weaponization of criminal law" for political purposes.

Finally, in a lighter vein, the Court remarked that political rivals often accuse each other of criminality only after losing office, likening every change of government to a new season bringing "a fresh crop of FIRs against the outgoing dispensation."

It added that government orders appear to transform “from routine administrative acts into alleged instruments of villainy, and back again with every election - much like Cinderella’s carriage turning into a pumpkin at midnight."

The Court ended the 173-page judgment with the following words: "यतो धर्मस्ततो जयः| Where there is dharma, there is victory. Justice, when upheld, triumphs overall."

Case Title: Nara Chandra Babu Naidu v. State of Andhra Pradesh and Anr with connected case

Date of Judgment: July 15, 2026

Bench: Justice Y. Lakshmana Rao