₹47,500 Found In Customs Officer’s Car: Karnataka HC Refuses To Quash CBI Corruption FIR Before Investigation

The petitioner, a Superintendent of Customs, challenged an FIR registered by the CBI on 22 January 2026 for offences under Sections 7 and 11 of the Prevention of Corruption Act, 1988, and Section 61(2) of the Bharatiya Nyaya Sanhita, 2023.

The FIR followed a joint surprise check at the Inland Container Depot, Whitefield, on 20–21 September 2024. During the check, ₹10,000 was found in a dustbin in the petitioner’s cubicle and ₹47,500 in his car; he had not declared the cash as required by departmental circulars.

The petitioner was not named in the initial proceedings and was later named after approvals were obtained; the CBI explained the delay by reference to the required approvals.

He sought to quash the FIR and consequential proceedings under Articles 226 and 227 of the Constitution and Section 528 of the BNSS.

Under the principles stated in Neeharika Infrastructure (P) Ltd. v. State of Maharashtra, an FIR is not an encyclopaedia of all facts, and a court should not assess the merits of allegations or prematurely halt an ongoing investigation on the basis of incomplete facts.

Somjeet Mallick v. State of Jharkhand reiterates that, at the threshold, the allegations and materials are taken at face value to determine whether a prima facie case for investigation is disclosed; their correctness is not tested, and the gravamen of the allegations—not omissions or the precise offence ultimately established—is considered.

The Court considered the alleged offences under Sections 7 and 11 of the Prevention of Corruption Act and Section 61(2) of the BNS, and the petitioner’s invocation of its jurisdiction under Articles 226 and 227 of the Constitution and Section 528 of the BNSS.

The Court noted that the FIR arose from the joint surprise check and alleged unexplained cash connected to the petitioner: ₹10,000 in a dustbin within his cubicle and ₹47,500 in his vehicle, which he had not declared.

Although the petitioner disputed that these circumstances established demand, acceptance, or receipt of illegal gratification, the Court declined to determine the merits while the matter remained at the FIR stage and no further investigation had taken place.

Applying the principle that an FIR need not set out every detail and that the allegations are assessed at face value at this stage, the Court held that it would be premature to terminate the investigation; it also noted that the case concerned alleged corruption.

It reserved the petitioner’s liberty to approach the appropriate forum at the appropriate time.