Parallel civil proceedings do not bar forgery prosecutions where the complaint discloses a prima facie criminal offence.

Pendency of a civil suit over the validity of a disputed document does not, by itself, justify quashing criminal proceedings alleging forgery or conspiracy. The power to quash at the threshold is to be used sparingly and only where the complaint, read as a whole, discloses no offence, there is a clear legal bar, or the case is a manifest abuse of process. Civil and criminal proceedings apply different standards of proof and serve different purposes. Where the record shows a prima facie case, the criminal process should continue notwithstanding parallel civil litigation. The complaint and process were restored for trial on merits.

---

---

Issues: Whether criminal proceedings alleging forgery and allied offences could be quashed at the threshold merely because a civil suit concerning the validity of the same document was pending.

Analysis: The power to quash criminal proceedings at the initial stage is to be exercised sparingly and only where the complaint, taken at face value, does not disclose any offence or where there is a clear legal bar or manifest abuse of process. The mere existence of parallel civil proceedings does not, by itself, justify quashing a criminal case. Civil and criminal proceedings proceed on different standards of proof and serve different ends. A dispute may have a civil profile, yet still disclose criminal offences such as forgery or conspiracy. Where the Magistrate has recorded statements and materials showing a prima facie case, the High Court should not short-circuit the prosecution only because the genuineness of the document is also under scrutiny in civil litigation.

Conclusion: The criminal proceedings could not be quashed solely on account of pendency of the civil suit, and the High Court's order quashing the complaint was unsustainable.

Final Conclusion: The complaint and process were restored for trial on merits, and the criminal court was to proceed in accordance with law notwithstanding the pending civil dispute.

Ratio Decidendi: Pendency of civil proceedings concerning a disputed document does not bar or warrant quashing of criminal proceedings alleging forgery or conspiracy where the complaint discloses a prima facie offence.

---