FIR quashed where property-dispute complaint disclosed no offence warranting investigation.

Respondent No. 2 alleged that, during a property dispute, the petitioners attempted to trespass onto her property, obstructed construction, abused her and threatened her on 12 October 2025.

Her complaint invoked Sections 189(2), 191(2), 329(3), 352, 351(2) and 190 of the Bharatiya Nyaya Sanhita, 2023 (BNS); Crime No. 15/2026 was registered following an order granting permission dated 5 March 2026.

The parties were also involved in a pending civil suit concerning the property, and the petitioners relied on earlier civil-court proceedings and a status quo order made by the High Court.

The petitioners sought to quash the permission order and FIR under Section 482 CrPC/Section 528 BNSS.

1. Whether the complaint disclosed an offence warranting investigation, such that Crime No. 15/2026 should be allowed to proceed.

2. Whether, in light of the pending civil dispute and the status quo order, further investigation served any purpose.

The petitions invoked the High Court’s inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973, corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to seek quashing of the proceedings.

The Court applied the principle that criminal proceedings may be quashed where the complaint’s contents do not disclose an offence warranting investigation.

The Court considered the complaint and the surrounding record, including the parties’ pending civil suit and the existence of other FIRs arising between them.

It viewed the alleged verbal abuse and threat as having arisen from the parties’ property dispute, noted that a status quo order had been made, and recorded that both sides would abide by the civil court’s eventual judgment and decree.

On that basis, it concluded that the complaint did not disclose an offence warranting investigation and that further investigation would serve no purpose.

The Court allowed both petitions and quashed the FIR dated 6 March 2026 in Crime No. 15/2026, pending before the Additional Civil Judge and JMFC, Pavagada.