Quashing of FIR on delayed complaint and pending civil proceedings rejected where disputed facts required investigation.

The Supreme Court of India held that an FIR alleging use of defeat devices could not be quashed at the threshold merely because the complaint was delayed or because related civil appeals arising from NGT proceedings were pending. The Court treated the alleged mismatch in vehicle numbers and the timing of the complaint as disputed questions of fact unsuitable for quashing jurisdiction. It further noted that the pending environmental proceedings did not prevent a private complainant from initiating criminal law, since those proceedings did not determine the purchaser-specific allegations of misrepresentation and installation of defeat devices. Investigation was therefore allowed to continue.

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Issues: Whether the FIR alleging use of defeat devices and related offences was liable to be quashed on the grounds of delay, disputed factual assertions, and the pendency of civil appeals arising from National Green Tribunal proceedings.

Analysis: The alleged discrepancy in the number of vehicles purchased and the complaint filed after delay raised disputed questions of fact, which could not be adjudicated in a petition to quash the FIR. Mere delay in lodging the complaint was not by itself a ground to terminate the criminal process. The pending civil appeals concerning the NGT order did not bar a private complainant from setting the criminal law in motion, because the NGT proceedings concerned broader environmental issues and did not determine the individual purchaser-specific allegations of misrepresentation and installation of defeat devices. The governing principles on quashing required restraint, and investigation could not be thwarted where the FIR disclosed allegations requiring factual inquiry.

Conclusion: The challenge to quashing of the FIR failed; investigation was permitted to continue.

Ratio Decidendi: An FIR cannot be quashed merely because it is alleged to be delayed or because connected civil or regulatory proceedings are pending, where the complaint raises disputed facts and discloses allegations warranting investigation.

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