A cheating FIR cannot be quashed where disputed transaction facts and transfer documents require investigation.

Respondent No. 2 alleged that the petitioner obtained her car on the pretext of taking his unwell mother to hospital, failed to return it despite demand, and later claimed it had been sold to him.

The petitioner relied on payments of ₹2 lakh and ₹3 lakh made in March 2020 and Forms 29 and 30 to assert that the vehicle had been sold to him. Respondent No. 2 disputed the purpose of the payments and alleged that her signatures on the forms were forged; the RTO had also rejected the transfer application.

Following a private complaint, Madanayakanahalli Police registered Crime No. 702/2024 under Sections 406 and 420 IPC. In the High Court, respondent No. 2 submitted that the prosecution would be confined to Section 420 IPC.

The petitioner sought quashing of the proceedings under Section 482 CrPC (Section 528 BNSS).

Whether the complaint and material available at the threshold ruled out an offence under Section 420 IPC, warranting quashing of the proceedings.

Whether the disputed transaction, payment purpose, and authenticity of Forms 29 and 30 could be determined in a quashing petition, or required investigation.

The Court considered Section 420 IPC and the High Court’s quashing jurisdiction under Section 482 CrPC (Section 528 BNSS).

At the quashing stage, the Court examines whether the allegations, taken at face value, disclose an offence and whether continuation of the investigation would amount to an abuse of process; it does not decide which of competing factual versions is correct.

The existence of a civil or contractual dispute does not, by itself, exclude criminal liability where the ingredients of an offence may otherwise be disclosed.

The petitioner’s account—that the payments were consideration for the vehicle and that the forms evidenced a sale—could bear on whether he had dishonest intent from the outset, but the complainant disputed both the payment purpose and the genuineness of the forms.

The timing of Form 29, the alleged forgery, the rejected transfer application, and the circumstances in which the petitioner obtained and retained the vehicle raised factual questions requiring investigation.

As those matters could not be resolved on the limited record, the allegations were neither inherently impossible nor so improbable as to make investigation an abuse of process.

It dismissed the petition and directed that the investigation proceed in accordance with law; if a charge sheet is filed, the petitioner may challenge it or seek discharge.