FIR quashing threshold: investigation cannot be stopped where allegations disclose prima facie offences beyond a company-law dispute.

An FIR should not be quashed at the threshold where the allegations, taken at face value, disclose offences beyond a narrow company-law grievance. The complaint here alleged not only non-return of company property but also forcible removal of rubber stamps and a letterhead pad, and their use to transfer a vehicle into the appellants' names; on those facts, a prima facie offence was disclosed. The settled quashing principles require restraint unless there is no offence, a legal bar, absurdity, or manifest mala fides, and none of those grounds was made out.

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Issues: Whether the first information report should be quashed in exercise of writ jurisdiction on the ground that the allegations, at best, disclosed only an offence relating to wrongful withholding of company property under the Companies Act.

Analysis: The allegations in the first information report were not confined to non-return of the company vehicle. They also included forcible removal of the company's rubber stamps and letterhead pad and use of them for transferring the vehicle into the appellants' names. In such circumstances, the complaint disclosed allegations beyond the limited grievance under the company law provision. The settled law is that investigation should not be interdicted at the threshold unless the complaint, even if taken at face value, discloses no offence or falls within the limited categories warranting quashing. The recognised grounds for quashing, including absence of a prima facie offence, legal bar, absurdity, or manifest mala fides, were not made out.

Conclusion: The request to quash the first information report was not justified and the appeal failed.

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