Supreme Court quashes FIR due to ulterior motive and lack of cognizable offense.

The Supreme Court of India quashed FIR No. 127 of 2022, finding it was filed with an ulterior motive and lacked disclosure of any cognizable offense under the IPC. The court applied the principles from the case of State of Haryana v. Bhajan Lal, emphasizing the absence of a prima facie case, inherent improbability, and mala fide intent. The court allowed the appeal, setting aside the High Court's order and quashing the criminal proceedings, clarifying that its decision was specific to this FIR and would not impact other pending prosecutions.

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1. ISSUES PRESENTED and CONSIDERED

The Supreme Court of India considered the following core legal questions in this judgment:

• Whether the First Information Report (FIR) No. 127 of 2022 should be quashedRs.
• Whether the allegations in the FIR constitute cognizable offences under the Indian Penal Code (IPC)Rs.
• Whether the FIR was filed with an ulterior motive for personal vengeanceRs.
• Whether the delay in filing the FIR affects its credibilityRs.

2. ISSUE-WISE DETAILED ANALYSIS

Issue 1: Whether the FIR should be quashedRs.

- Relevant legal framework and precedents: The court referred to the parameters laid down in the case of State of Haryana v. Bhajan Lal for quashing an FIR, which include situations where the allegations do not constitute an offence, are inherently improbable, or are made with mala fide intent.

- Court's interpretation and reasoning: The court found that the FIR was lodged after a significant delay of 14 years without any specific date or time of the alleged offences. The allegations appeared to be concocted and fabricated.

- Key evidence and findings: The FIR lacked specific details and was filed long after the alleged incidents, which cast doubt on its credibility.

- Application of law to facts: The court applied the principles from Bhajan Lal and found that the case fell within the parameters for quashing the FIR, specifically under points 1, 5, and 7, which relate to the absence of a prima facie case, inherent improbability, and mala fide intent.

- Treatment of competing arguments: The appellants argued that the FIR was filed with an ulterior motive and highlighted the improbability of the allegations. The State contended that the FIR disclosed cognizable offences and that delay should not be a ground for quashing.

- Conclusions: The court concluded that the FIR should be quashed as it was filed with an ulterior motive and did not disclose any cognizable offence.

3. SIGNIFICANT HOLDINGS

- Preserve verbatim quotes of crucial legal reasoning: "We are of the view that even if the entire case of the prosecution is believed or accepted to be true, none of the ingredients to constitute the offence as alleged are disclosed."

- Core principles established: The judgment reinforced the principles for quashing an FIR as laid out in Bhajan Lal, emphasizing the need to assess the FIR for inherent improbability and mala fide intent.

- Final determinations on each issue: The court determined that the FIR No. 127 of 2022 should be quashed as it was filed with an ulterior motive and did not disclose any cognizable offence under the IPC.

In conclusion, the Supreme Court allowed the appeal, setting aside the High Court's order and quashing the criminal proceedings arising from FIR No. 127 of 2022. The court clarified that its observations were relevant only for the purpose of this FIR and would not affect any other pending criminal prosecutions or proceedings.

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