FIRs alleging cognizable offences in forged public records should not be quashed before investigation.

The petitions arose from allegations that public officials had created or forged revenue and survey records concerning approximately five acres of tank-bund land in Survey No. 75 of Navaratna Agrahara Village, later assigned Survey No. 163.

A complaint by revenue and survey officials led to Yelahanka Police registering Crime No. 22/2017 for offences under the IPC and Section 192A of the Karnataka Land Revenue Act, 1964.

A separate complaint by the Joint Director of Land Records led the Anti-Corruption Bureau (now Lokayukta) to register Crime No. 16/2017 for offences under the Prevention of Corruption Act and the IPC.

The petitioners, including a Tahsildar, surveyors and a Village Accountant, sought quashing of the respective complaints, FIRs and related notice or proceedings under Section 482 CrPC.

They disputed their involvement, questioned the timing of the alleged acts and contended, among other things, that two FIRs had been registered concerning the same matter.

Whether the complaints and FIRs should be quashed at the investigation stage where they alleged forgery and creation of revenue and survey records relating to State land.

Whether the registration of separate FIRs by the police and the Lokayukta concerning the alleged acts warranted quashing of the proceedings.

Section 482 CrPC permits the High Court to prevent abuse of process, but the court should not assess disputed evidence or draw its own factual inferences when an FIR discloses a prima facie cognizable offence; investigation should ordinarily proceed so the allegations can be tested on the collected material.

The Court relied on Dineshbhai Chandubhai Patel v. State of Gujarat, (2018) 3 SCC 104, for this restraint in quashing FIRs.

It also considered Anju Chaudhary v. State of U.P., 2013 AIR SCW 245, and Amitbhai Anilchandra Shah v. CBI, W.P. (Crl.) No. 5/2013, on the principles concerning multiple FIRs and the same occurrence or transaction.

The Court noted that the Lokayukta could investigate offences under the Prevention of Corruption Act, while the earlier police FIR concerned IPC and Karnataka Land Revenue Act offences.

The complaints contained specific allegations that officials’ signatures had been forged and revenue and survey documents created in relation to government tank-bund land.

Whether the alleged manipulation occurred during the petitioners’ periods of service, and what role each petitioner had, required investigation; those disputed matters could not be determined in petitions seeking quashing at this stage.

The Court also declined to quash on the basis of the two-FIR objection.

It treated the police and Lokayukta cases as arising from complaints to different agencies concerning different statutory offences, and held that investigation should proceed to establish the facts and any overlap.

It declined to quash the complaints, FIRs, notice or related proceedings, leaving the investigating agencies to investigate the alleged creation of forged revenue and survey records and the petitioners’ respective roles.