Pre-investigation FIR quashing is impermissible where disputed facts require investigation before merits are assessed.

A court exercising inherent jurisdiction should not quash an FIR on a disputed factual appraisal before investigation has commenced. Where the complaint contained specific allegations of cruelty, abuse, assault and dowry demand, the FIR could not be tested on merits by relying on statements from divorce proceedings at the pre-investigation stage. Such material was for the investigating agency or the criminal court at a later stage. The High Court's quashing order was therefore premature and unsustainable, and the FIR was restored so that investigation could proceed in accordance with law.

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Issues: Whether the High Court was justified in quashing the FIR under Section 482 of the Code of Criminal Procedure, 1973 at a stage when investigation had not commenced.

Analysis: The complaint contained specific allegations of cruelty, abuse, assault and demand of dowry, and the FIR had been registered on that basis. The High Court relied on statements made in a divorce proceeding and treated the matter as though it were deciding the criminal liability on merits. At the stage of a petition for quashing, before investigation begins, the court is not expected to assess the truth of allegations or examine whether material will ultimately support a charge-sheet. Such material, including findings in civil proceedings, may at best be considered by the investigating agency or the criminal court at a later stage.

Conclusion: The High Court's order quashing the FIR was premature and unsustainable. The FIR was directed to be restored and investigation was ordered to proceed.

Final Conclusion: Interference at the pre-investigation stage was held to be unwarranted, and the criminal process was allowed to continue in accordance with law.

Ratio Decidendi: A court exercising inherent jurisdiction should not quash an FIR on a factual appraisal of disputed materials before investigation has commenced.

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