Special tax investigation machinery does not exclude police inquiry into cognate IPC offences where cognizable wrongdoing is disclosed.

Section 4(2) CrPC permits investigation and trial of offences under other laws unless the special statute expressly regulates a different procedure, and the West Bengal Sales Tax Act, 1994 did not exclude police action for cognate IPC offences. The Act's Bureau of Investigation was created to investigate tax evasion and related malpractices, but that special machinery did not displace ordinary police powers where IPC offences surfaced during the inquiry. Section 88(6) also indicated that sales tax offences operate in addition to other legal penalties. The FIR was therefore not liable to be quashed, and the police investigation could continue.

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Issues: Whether offences under the Indian Penal Code, when clubbed with offences under the West Bengal Sales Tax Act, 1994, could be investigated by the police and whether the FIR was liable to be quashed on the ground that the complaint had been forwarded by an officer other than the Bureau of Investigation.

Analysis: Section 4(2) of the Code of Criminal Procedure, 1973 makes offences under other laws triable under the Code unless the special statute contains a contrary provision regulating the manner or place of investigation, inquiry or trial. The West Bengal Sales Tax Act, 1994 created a Bureau of Investigation under section 7 to investigate tax evasion and related malpractices, but nothing in section 7 excluded the ordinary police from investigating cognate offences under the Indian Penal Code or from acting where such offences surfaced during the inquiry. Section 88(6) expressly makes the sales tax offence supplemental to other penalties under law, which negatives any inference that IPC offences are displaced. Quashing the FIR merely because the police were set in motion would not further the ends of criminal justice, particularly when the FIR disclosed serious cognizable offences.

Conclusion: The FIR was not liable to be quashed, and the police investigation could proceed notwithstanding the special machinery under the Sales Tax Act.

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