Contemporaneous complaints raising disputed allegations warrant investigation, not quashing at the threshold.

Respondent No. 2 alleged that the petitioner had received ₹62,000 in connection with her case and later refused to refund it; she also alleged threats and an attempted assault.

She first approached the Bar Association on 14 November 2024 and later lodged a police complaint on 14 December 2024.

The petitioner had also lodged a complaint on 14 November 2024, resulting in Crime No. 195/2024 against respondent No. 2.

The petition sought to quash FIR No. 214/2024, registered for alleged offences under Sections 351, 352 and 74 of the Bharatiya Nyaya Sanhita, 2023 (BNS).

The judgment recounts rival complaints concerning events during substantially the same period, while noting that whether they arose from the same chain of events remained undetermined.

Whether the FIR challenged by the petitioner should be quashed under the High Court’s inherent jurisdiction

Whether the allegations and disputed circumstances required investigation rather than assessment by the High Court at the quashing stage

The petition invoked Section 482 of the Code of Criminal Procedure, 1973, and Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, concerning the High Court’s inherent jurisdiction.

The Court applied the principle that, at this stage, it should not conduct a roving inquiry into disputed facts or assess the evidentiary worth of rival allegations; where the allegations require factual ascertainment, the investigation should not be interdicted prematurely.

Sections 351, 352 and 74 of the BNS were the offences specified in the challenged FIR.

The contemporaneous approach by respondent No. 2 to the Bar Association on 14 November 2024, followed by her police complaint, meant that her allegations could not be dismissed at this stage solely by assessing their truth against the petitioner’s defence.

The rival complaints concerned events during substantially the same period, but the Court could not determine whether they arose from the same sequence of events or from separate incidents without factual investigation.

It therefore declined to evaluate the disputed facts or evidentiary merits and held that investigation should proceed.

It reserved liberty to the petitioner to raise any available defence before the trial Court.