An FIR alleging forgery and criminal intimidation should not be quashed merely as a monetary dispute.

The complainant alleged that she and her daughter invested a total of ₹8,00,000 in the petitioners’ online-trading business in three instalments between November 2018 and February 2020.

The petitioners allegedly issued a cheque and forged investment agreements, failed to repay the full amount, and threatened the complainant when repayment was demanded.

The petitioners acknowledged receiving the amount and repaying ₹1,60,000, but claimed the dispute was civil in nature and arose from a separate loan and cheque transaction.

The daughter had also brought a cheque-dishonour case against them, in which the petitioners had been convicted and an appeal was pending.

Following a complaint to the Magistrate and a direction to register a case, the police registered an FIR for offences under Sections 420, 467, 471 and 506(ii) IPC.

The petitioners sought to quash it under Section 482 Cr.P.C.

Whether the FIR alleging cheating, forgery, use of forged documents and criminal intimidation should be quashed under Section 482 Cr.P.C. as arising from a purely civil or monetary dispute.

Whether the pending cheque-dishonour proceedings and the petitioners’ alleged partial repayment warranted quashing the FIR at the investigation stage.

Section 482 Cr.P.C. preserves the High Court’s inherent power to prevent abuse of process and secure the ends of justice, but that power is to be exercised sparingly.

Relying on Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, Criminal Appeal No. 330 of 2021, the Court reiterated that quashing an FIR at the investigation stage is generally inappropriate where the allegations disclose cognizable offences; courts should not prematurely assess the merits on incomplete or disputed facts, and the police should ordinarily be permitted to investigate.

The alleged offences were under Sections 420, 467, 471 and 506(ii) IPC.

The Court noted that the petitioners did not dispute receiving ₹8,00,000 or repaying ₹1,60,000, leaving an alleged balance of ₹6,40,000; it also noted their assertion that the cheque was issued as security.

However, the complaint additionally alleged forged agreements, dishonest non-repayment and threats—allegations which, if investigated, could disclose the charged offences.

The cheque-dishonour case and the monetary nature of the dealings did not, in the Court’s view, establish that the FIR was an abuse of process or eliminate the need to investigate the distinct allegations.

The Court therefore declined to determine disputed facts at the quashing stage.

It directed the first respondent to complete the investigation and file a final report within three months of receiving a copy of the order; the connected miscellaneous petition was closed.