Detailed forgery allegations disclosing cognizable offences warrant investigation, not quashing.

The petitioner, arrayed as accused No. 4, sought to quash the FIR in Crime No. 13/2024, registered for alleged offences under Sections 34, 420, 467, 468, 470 and 471 IPC.

The complainant alleged that the petitioner and others relied on a forged power of attorney to execute a lease deed concerning property owned by her late father.

The Court noted that accused Nos. 1 to 3 had previously sought quashing of the same FIR on the basis of substantially similar allegations; their petition was dismissed on 22 September 2025.

1. Whether the FIR and investigation against accused No. 4 should be quashed under Section 482 CrPC, notwithstanding the dismissal of the co-accused’s petition and the similarity of the allegations against them.

2. Whether the dispute’s connection to property and related civil remedies warranted quashing of the criminal proceedings.

The High Court’s inherent power under Section 482 CrPC (the petition also referred to Section 528 BNSS) is to be exercised sparingly; proceedings should not be quashed where the allegations, taken at face value, disclose cognizable offences requiring investigation.

The Court relied on the principle that civil and criminal remedies may proceed concurrently, and that the existence or pendency of civil proceedings does not, by itself, bar criminal prosecution. The incorporated order applied authorities including State of Haryana v. Bhajan Lal, P. Swaroopa Rani v. M. Hari Narayana, Kathyayini v. Sidharth P.S. Reddy, Priti Saraf v. State (NCT of Delhi) and Punit Beriwala v. State (NCT of Delhi).

The Court relied on its earlier decision concerning accused Nos. 1 to 3, which had found that the complaint contained detailed allegations of forgery and fraud and disclosed the ingredients of the alleged offences, making police investigation necessary.

It found that the allegations against accused No. 4 were identical or similar in nature to those against the co-accused. In light of that determination, and because the alleged criminal conduct could not be resolved merely by pointing to a civil dimension, the Court found no basis to exercise its inherent jurisdiction to stop the investigation.

The FIR and investigation against the petitioner were not quashed.