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Issues: Whether the First Information Report and consequential proceedings were liable to be quashed in exercise of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973, when the allegations disclosed cognizable offences and the investigation was at a nascent stage.
Analysis: The governing principles emphasise that investigation into a cognizable offence should not ordinarily be thwarted, and the Court should not undertake an enquiry into the truth, reliability, or genuineness of the allegations at the threshold. Quashing is an exceptional remedy to be used sparingly, and only where the allegations do not disclose any cognizable offence or where non-interference would result in miscarriage of justice. The petitioner's defence based on documents and factual assertions was a matter for investigation and could not justify quashing at this stage, particularly when the petitioner had not joined investigation and had instead sought to terminate the criminal process.
Conclusion: The petition for quashing was not maintainable on merits and the First Information Report and connected proceedings were not liable to be interfered with under Section 482 of the Code of Criminal Procedure, 1973.