Investigation into cognizable offenses cannot be quashed when factual disputes regarding license validity require trial.

The petitioners (employees/relatives of a registered Inter-State Agriculture Cattle Trader) were transporting ten buffaloes on foot near village Pondi-Shankar on 05.04.2026.

Police intercepted them and, alleging failure to produce valid documentation at the site, registered FIR No. 36/2026 at Police Station Bamhnidih under Sections 4, 6, and 10 of the Chhattisgarh Agricultural Cattle Preservation Act, 2004, and Section 11(D) of the Prevention of Cruelty to Animal Rules, 1960.

The petitioners moved the High Court under Section 528 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), seeking quashing of the FIR on the grounds that the business was lawful, cattle were purchased via valid receipts, and the owner possessed a valid registration.

1. Whether the FIR and subsequent proceedings should be quashed under Section 528 of the BNSS on the ground that the petitioners were engaged in a lawful trade with valid documentation.

2. Whether the High Court, in a quashing petition, can adjudicate upon disputed questions of fact and defense evidence regarding the validity of transportation licenses.

Section 528 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, which provides inherent powers to the High Court to prevent abuse of the process of law.

Established principles of criminal jurisprudence which dictate that an FIR should not be quashed if it prima facie discloses cognizable offences.

In quashing proceedings, the High Court must not conduct a "meticulous examination of evidence" or adjudicate upon the "defence of the accused".

The Court observed that the FIR, on its face, disclosed the commission of cognizable offences related to the illegal transportation and preservation of agricultural cattle.

While the petitioners claimed they held valid licenses and were acting within the scope of lawful employment, the Court held that these are "disputed questions of fact" that cannot be resolved in a summary proceeding under Section 528 BNSS.

The Court reasoned that the circumstances of the interception, the adequacy of the documents at the time of seizure, and the manner of transportation are matters for a thorough investigation.

Therefore, since the allegations constitute a triable case, the Court found no evidence of "abuse of process of law" or "miscarriage of justice" that would justify stifling the prosecution at the threshold.

The High Court dismissed the petition, holding that the case does not meet the exceptional parameters required for quashing an FIR.

The Court clarified that its observations are restricted to the present petition and shall not prejudice the subsequent investigation or trial.