Inherent jurisdiction cannot cut short investigation when an FIR discloses a prima facie cognizable offence.

The Supreme Court of India stated that, when complaints and an FIR disclose a prima facie cognizable offence, the High Court's role under Section 482 is limited to that threshold inquiry. It cannot function as an investigating agency or appellate forum, assess disputed material, or draw factual inferences at that stage. Where the FIR discloses prima facie commission of cognizable offences, investigation must be permitted to proceed in accordance with law. On that basis, the High Court was said to have exceeded the limits of its inherent jurisdiction by partly quashing the FIR.

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Issues: Whether the High Court exceeded its jurisdiction in partly quashing the FIR under Section 482 of the Code when the complaints and FIR disclosed a prima facie cognizable offence.

Analysis: The complaints and FIR were required to be tested only to see whether they disclosed a prima facie cognizable offence. At that stage, the High Court could not act as an investigating agency or an appellate court, nor could it assess disputed material or draw factual inferences. Once the FIR disclosed prima facie commission of cognizable offences, the investigation ought to have been allowed to proceed in accordance with law.

Conclusion: The High Court exceeded the limits of its inherent jurisdiction in partly quashing the FIR; the complainants' appeals were allowed and the accused persons' appeals were dismissed.

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