Investigating officers must consider accused-produced defence documents before filing the final report.

The petitioners, arrayed as accused in Crime No. 881/2023, sought quashing of the FIR registered by Mahadevapura Police for offences under Sections 34, 417 and 420 of the IPC

They contended that respondent No. 2 had earlier filed O.S. No. 3988/2021 seeking declaratory relief, but the plaint was rejected under Order VII Rule 11 CPC on 11 April 2022; the criminal complaint, said to concern the same cause of action, was filed about one and a half years later

The State opposed quashing on the ground that the investigation was at a nascent stage

1. Whether the FIR should be quashed on the petitioners’ contention that the complaint arose from the same cause of action as the earlier civil suit and was filed to wreak vengeance

2. Whether the petitioners could place their defence documents before the Investigating Officer for consideration during the ongoing investigation

The petitions invoked the High Court’s inherent jurisdiction under Section 482 of the CrPC to seek quashing of the FIR; the alleged offences were under Sections 34, 417 and 420 of the IPC

The Court cited no precedent and did not set out a separate test for quashing or determine the ingredients of the alleged offences.

Its operative direction was that the petitioners could submit their relied-upon documents to the Investigating Officer, who was to consider them in accordance with law before filing the final report

The petitioners relied on the rejection of the earlier civil plaint and the asserted overlap between that suit and the criminal complaint to support their allegation of vengeance

The State, however, submitted that the investigation remained at a nascent stage

The Court did not decide whether the civil proceedings warranted quashing the FIR or assess the merits of the allegations. Instead, it provided a procedural course for the petitioners to place their defence documents before the Investigating Officer for consideration in accordance with law

The petitioners were granted liberty to submit their relied-upon documents to the Investigating Officer within two weeks of receiving a copy of the order, and the Investigating Officer was directed to consider those documents in accordance with law before filing the final report