A civil dispute cannot bar investigation when the complaint prima facie discloses cognizable offences.

The petitioner claimed ownership of land in Paiyanoor Village under registered sale deeds executed in 2005, with revenue records and patta issued in his name.

He alleged that Respondents 3 and 4 had created or relied on false title documents concerning overlapping property, including a settlement deed and release deed registered in 2014.

After a police complaint in 2024 did not result in an FIR, he sought a direction under Section 175(3) of the BNSS.

The Judicial Magistrate dismissed the petition on the ground that the dispute was civil in nature; the petitioner challenged that order in revision.

Whether the complaint, read as a whole, prima facie disclosed cognizable offences warranting police investigation under Section 175(3) of the BNSS.

Whether the Magistrate could refuse to direct investigation on the ground that the dispute concerned civil rights and title to property.

Section 175(3) of the BNSS empowers a Magistrate to order police investigation where a complaint prima facie discloses cognizable offences; the Magistrate’s task at this stage is not to adjudicate the allegations, resolve competing factual versions, or determine civil rights.

Civil and criminal remedies may coexist: the existence of a civil dispute or remedy does not bar criminal investigation where the alleged facts independently disclose cognizable offences.

The Court relied on Accamma Sam Jacob v. State of Karnataka (2026 INSC 362), Nazibul Rahimkhan v. State of U.P. (2026 INSC 619), State of M.P. v. Shilpa Jain (2024 SCC OnLine SC 507), Rocky v. State of Telangana (2025 INSC 1384), and C.S. Prasad v. C. Satyakumar (2026 INSC 39) for these principles.

The complaint identified the alleged participants, the properties and documents in dispute, and the steps taken to approach the police; the Court therefore considered it sufficiently particularised to justify investigation.

At the Section 175(3) stage, the Magistrate was not to determine title or assess the truth of the rival claims. By treating the dispute as purely civil and refusing investigation, the Magistrate had, in the High Court’s view, prematurely evaluated the matter.

Since the allegations, taken prima facie, disclosed cognizable offences including forgery, cheating and conspiracy, the civil character of the underlying property dispute did not justify declining investigation.

It remanded the matter to the Judicial Magistrate-II, Chengalpattu, with a direction to pass an appropriate order directing the second respondent police to register an FIR, investigate the matter properly and submit a report in accordance with law, within eight weeks of receipt of a certified copy of the judgment.

No order as to costs was made.