Quashing of FIR limited where allegations disclose cognizable offences and disputed facts require trial-level determination.

An FIR alleging forgery and cheating in relation to a sale deed, and disclosing cognizable offences, cannot be quashed under the High Court's inherent jurisdiction under Section 482 CrPC where the controversy turns on disputed questions of fact. The allegations were distinct from an earlier complaint between the parties, and the factual disputes were unsuitable for determination in a quashing petition. Applying the settled principles on quashing of FIRs, the court found no basis for interference and dismissed the petition.

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Issues: Whether the FIR registered for offences under the Indian Penal Code could be quashed in exercise of inherent powers under Section 482 of the Code of Criminal Procedure, 1973.

Analysis: The allegations in the impugned FIR were found to be distinct from the earlier complaint between the parties. The complaint disclosed allegations of forgery and cheating relating to a sale deed, which presented disputed questions of fact unsuitable for determination in a petition under Section 482 of the Code of Criminal Procedure, 1973. The complaint also disclosed commission of cognizable offences. In such circumstances, the principles governing quashing of FIRs did not justify interference.

Conclusion: The FIR was not liable to be quashed and the petition was dismissed.

Ratio Decidendi: An FIR disclosing cognizable offences and involving disputed questions of fact cannot be quashed in exercise of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973.

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