Premature quashing of FIR during incomplete investigation is impermissible where material requires full inquiry.

Quashing of an FIR under Section 482 CrPC was held premature where the investigation was still incomplete. The Court noted that recovery of a large cash amount from an accused's house and the explanation for its source were matters requiring investigation, not final assessment at the quashing stage. Because the allegations and surrounding circumstances disclosed sufficient material to allow the probe to continue, the High Court should not have entered into the merits before the investigation reached its logical conclusion. The quashing order was unsustainable, and the FIR and investigation were restored.

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Issues: Whether the High Court was justified in quashing the FIR and criminal proceedings under Section 482 of the Code of Criminal Procedure, 1973 while the investigation was still incomplete.

Analysis: The recovery of a large amount of cash from the house of one accused and the explanation offered for its source were matters that required investigation and could not be conclusively assessed at the quashing stage. The High Court entered into the merits prematurely, although the investigation had not reached its logical conclusion. At that stage, the allegations and surrounding circumstances disclosed sufficient material to permit the investigation to continue.

Conclusion: The quashing order was unsustainable and interference by the High Court was unjustified. The FIR and investigation were restored.

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