Kerala Financial Corp Secures Return of Seized Title Deeds

Supreme Court of India, Criminal Appellate Jurisdiction

18 August 2026

Parties: Appellant – The Branch Manager, Kerala Financial Corporation (KFC); Respondents – Muhammad Iqbal and others.
Background: Respondent No.1 (Muhammad Iqbal) entered a sale agreement for a landed property with respondent No.6. Respondents 6 and 7 subsequently mortgaged the same property with KFC to obtain a loan of Rs 40 lakhs, pledging the original title deeds as security.
Criminal proceedings: A criminal case for impersonation was filed by respondent No.1 against respondents 6 and 7. During investigation, the title deeds were seized from KFC’s possession.
Section 451 CrPC application: Respondent No.1 filed an application under Section 451 of the CrPC seeking release of the seized deeds. The Special Court dismissed the application on 05‑05‑2022, stating that release would prejudice the trial.
High Court order: The Kerala High Court, while imposing conditions, directed the Special Court to hand over the seized title deeds to respondent No.1.
Appellant’s submissions: KFC, a state financial corporation, contended that it is neither an accused nor a complainant and that it is not a party to the criminal proceedings; therefore, the deeds should not be released.
Additional procedural order: The Court also ordered deletion of proforma respondents No.5 and No.9 from the array of parties and amendment of the cause title accordingly.

The Supreme Court set aside the High Court’s order directing the handover of the title deeds.
The Court directed respondent No.1 to deposit the title deeds with the Special Court within four weeks from the date of the order; the Special Court shall then return the deeds to KFC for safe custody and production before it as required.
The appeal is allowed, and any pending applications are disposed of.

Legal Procedure, Property Dispute