Accused may submit defence documents for consideration before the final report; coercive steps are barred until then.

Respondent No. 4 in Criminal Petition No. 11514 of 2024 alleged that the petitioners had forged documents relating to Site No. 204 (Old No. 206), Kithiganur Village.

The petitioners maintained that Petitioner No. 1 had purchased the property by a sale deed dated 19 July 2016, possessed it, and later sold it to Petitioner No. 2; they contended that the complainant’s property was separate.

The complainant had filed a private complaint, PCR No. 626/2024, and a police complaint, following which criminal proceedings and an FIR were initiated against the petitioners.

The petitioners sought to quash the FIR and the private-complaint proceedings.

The State submitted that the investigation was at an early stage and that, apart from registering the FIR, the police had not investigated because of an interim order.

1. Whether the FIR and the proceedings arising from the private complaint should be quashed at that stage, in light of the petitioners’ account of the property transactions and the pending investigation.

2. Whether the petitioners should instead be permitted to place their supporting documents before the Investigating Officer, with protection from coercive steps in the interim.

The petitions invoked Section 482 of the Code of Criminal Procedure, 1973, described in the pleadings as filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

The FIR alleged offences under Sections 120B, 420, 447, 465, 468 and 416 of the Indian Penal Code. The order does not discuss the elements of these offences, cite precedent, or set out a substantive quashing test; it instead directs the petitioners to present their defence documents to the Investigating Officer for consideration during the investigation.

The Court recorded the competing positions: the petitioners relied on their sale deed and asserted that the complainant’s property was distinct, while the State emphasized that the investigation had barely begun.

Rather than determine the disputed property and forgery allegations or quash the proceedings at that stage, the Court permitted the petitioners to submit the sale deed and other documents to the Investigating Officer. It directed the Officer to consider those materials in accordance with law before filing the final report.

It granted the petitioners liberty to provide their relied-upon documents to the Investigating Officer within two weeks of receiving the order, directed the Officer to consider them before filing the final report, and ordered that no coercive steps be taken against the petitioners until then.