Quashing of FIR requires strict limits; general CBI notification was sufficient and jurisdictional challenge failed.

Section 482 CrPC permits quashing only in exceptional cases where allegations disclose no offence, a legal bar exists, or continuation would amount to abuse of process. The Court held that under Sections 3, 5 and 6 of the Delhi Special Police Establishment Act, a general notification extending Special Police Establishment powers is sufficient and individual notification of each officer is not required. An inter-departmental letter could not be treated as a valid rescission of the earlier State consent or notification, and it did not satisfy Article 166 requirements. The FIR therefore could not be quashed for want of jurisdiction, and the proceedings were allowed to continue.

---

---

Issues: Whether the High Court was justified in quashing the FIR on the ground that the Central Bureau of Investigation lacked jurisdiction because the State consent/notification under the Delhi Special Police Establishment Act had been withdrawn and no individual authorization of officers had been issued.

Analysis: The scope of Section 482 of the Code of Criminal Procedure, 1973 is exceptional and must be exercised sparingly to prevent abuse of process or to secure the ends of justice. Quashing is permissible only where the allegations do not disclose an offence, where there is a clear legal bar, or where continuance of proceedings would be an abuse of process. Under Sections 3, 5 and 6 of the Delhi Special Police Establishment Act, 1946, a general notification extending the powers of the Special Police Establishment is sufficient; there is no requirement that every officer be individually notified. The alleged revocation relied upon by the respondent was only an inter-departmental letter, not a notification, and the authority of the maker of that letter was not established. It therefore could not be treated as rescinding the earlier consent or notification. Article 166 of the Constitution of India was also not satisfied by such a letter.

Conclusion: The High Court was not justified in quashing the proceedings, and the FIR could not be invalidated on the ground of want of jurisdiction.

---