Inherent jurisdiction to quash FIR must be exercised sparingly and cautiously during ongoing investigations.

The petitioner originally lodged an FIR against several individuals (Respondents 2-7) alleging a fraudulent investment scheme under the name "Subh Nivesh Stock Trading Company," claiming he and his relatives were defrauded of Rs. 75,00,000/-

During the subsequent police investigation into FIR No. 715 of 2024, the petitioner—despite being the initial complainant—was arrayed as a co-accused for offences under Sections 420 and 120-B of the IPC, Sections 111 and 317(4) of the Bhartiya Nyay Sahinta (BNSS), and various provisions of the Prize Chits and Money Circulation Schemes (Banning) Act and the Chhattisgarh Protection of Depositors Interest Act

The petitioner was arrested on September 14, 2025, and later enlarged on bail

He filed the present petition to quash the FIR, arguing he is a victim of the scam and that his inclusion as an accused is an abuse of process

The State opposed the petition, noting that the investigation is ongoing and that quashing petitions by other co-accused in the same FIR had already been dismissed

Whether the High Court should exercise its inherent jurisdiction to quash an FIR when the investigation is still in progress and the final police report has not yet been filed.

Whether the status of the petitioner as the original informant precludes his arrayal as a co-accused if material evidence suggests involvement.

Section 528 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023 (the successor to Section 482 of the Cr.P.C.), which governs the inherent powers of the High Court

established principle that the power to quash an FIR must be exercised sparingly and with extreme caution

interference is warranted only if the allegations, on their face, do not disclose an offence or if the proceedings are manifestly mala fide

procedural requirement for filing a police report under Section 173(2) of the Cr.P.C. (now Section 193(3) of the BNSS)

since the investigation into the stock trading scam is still at a "crucial stage" and has not yet culminated in a final police report, it would be premature to conclusively determine the petitioner's role

a petitioner’s status as the initial informant does not ipso facto grant immunity from prosecution if subsequent investigative findings indicate complicity

The court declined to delve into the merits of the allegations to avoid prejudicing the ongoing probe

Noting that similar challenges by co-accused had been dismissed, the court found that the petitioner failed to demonstrate "exceptional circumstances" required for interference at the pre-charge sheet stage

Consequently, the court determined that the proper course of action was to ensure the investigation concluded promptly rather than quashing the proceedings

The court held that it was not inclined to interfere with the ongoing investigation at this premature stage

the court directed the Investigating Officer to expedite the probe and submit the final police report under Section 193(3) of the BNSS before the competent court within six weeks

The petitioner was granted liberty to challenge the final report before the appropriate forum if he remains aggrieved following its submission