Quashing is impermissible where prima facie conspiracy exists and disputed facts require trial.

The second respondent alleged that A1, in collusion with A2 to A7, fabricated Sale Deed Document No.3994 of 1975 dated 20.10.1975 by converting a mortgage deed into a sale deed in the records of the Sub-Registrar Office, Tambaram.

The accused allegedly altered index registers, uploaded the purported sale deed, and relied on it to obtain patta over specified properties belonging to the second respondent.

Following the High Court’s direction in W.P.No.11751 of 2021, Crime No.2 of 2022 was registered for offences including conspiracy, trespass, mischief, theft and forgery.

After investigation, a final report was filed and cognizance was taken in C.C.No.123 of 2026 by the XI Metropolitan Magistrate, Saidapet, for offences under Sections 120B, 420, 448, 465, 467, 468 and 471 IPC.

The petitioners, arrayed as A3 to A6, sought quashing of the proceedings under Section 482 CrPC.

Whether the materials collected during investigation disclosed a prima facie case of conspiracy, forgery, cheating and use of forged documents against the petitioners so as to justify continuation of C.C.No.123 of 2026?

Whether the petitioners’ defences— including unauthorised misuse of login credentials, absence from the office, lack of knowledge, and performance of official duties—could be adjudicated in a petition for quashing under Section 482 CrPC?

Whether the repeated approval of index corrections by A6, the District Registrar, was sufficient at the threshold to require adjudication at trial rather than quashing of the proceedings?

The Court applied Section 482 CrPC, which permits the High Court to quash criminal proceedings only where the allegations and materials do not disclose an offence or where continuation of the proceedings would otherwise amount to abuse of process; it held that disputed factual questions and the sufficiency of evidence cannot ordinarily be determined at that stage.

The Court considered Sections 120B, 420, 448, 465, 467, 468 and 471 IPC, observing that forgery, making or using a forged document, and cheating must be assessed with reference to the alleged knowledge and intention, and that proof of monetary gain by every accused is not indispensable.

It relied on Devendra Prasad Singh v. State of Bihar, 2019 (4) SCC 351, for the principle that the High Court should not assess witness inconsistencies while exercising quashing jurisdiction; CBI v. Arvind Khanna, 2019 (10) SCC 686, for the rule that disputed facts and defence evidence must be tested at trial; and M. Jayanthi v. K.R. Meenakshi, Crl.A.No.1817 of 2019, for the principle that the Court must only examine whether the allegations, taken at face value, disclose the ingredients of the alleged offences and should not conduct a detailed evaluation of evidence.

The Court found prima facie material indicating that the accused acted in concert to introduce, upload and correct entries relating to the allegedly forged sale deed.

The repeated use of official login credentials, uploading of the document on several dates, correction of title and property particulars, and forwarding of the documents for approval constituted circumstances connecting the petitioners to the alleged conspiracy; the prosecution did not rely solely on login records.

The petitioners’ claims that their credentials were misused, that they were not physically present, or that they acted without knowledge raised disputed factual questions requiring oral and documentary evidence.

Such questions could not be conclusively resolved under Section 482 CrPC.

As regards A6, the Court held that his repeated approval of corrections concerning the same document on three occasions could not, at the threshold, be treated as a wholly innocuous discharge of official duty.

Since he was the final approving authority and was expected to scrutinise corrections concerning title, ownership, survey numbers and extent, the prosecution material was sufficient to require a trial.

The availability of any official or statutory protection was also left open for determination on the evidence.

Accordingly, the Court concluded that the proceedings were not manifestly groundless or an abuse of process.

The petitions seeking quashing of C.C.No.123 of 2026 were therefore dismissed, and the connected miscellaneous petitions were closed.