Quashing of FIR at the threshold requires a disclosed cognizable offence; untested allegations cannot be rejected as insufficient.

At the quashing stage, an FIR must be read as it stands, and the court cannot test the truth, reliability, or sufficiency of the allegations. Where the uncontroverted facts disclose a cognizable offence, criminal investigation should not be stifled and quashing remains an exceptional remedy. On the stated facts, the FIR referred to service of a prohibitory order under section 132(3) of the Income-tax Act, alleged breach of that restraint, and locker operation supported by bank officials' statements and CCTV material; the court held that these allegations were sufficient to permit investigation and declined to quash the FIR.

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Issues: Whether the First Information Report was liable to be quashed on the ground that the allegations, even if taken at face value, did not disclose a cognizable offence against the petitioner and that the dispute was at best an issue under the Income-tax Act, 1961.

Analysis: The allegations in the FIR were accepted as they stood at the stage of quashing. The materials disclosed that a prohibitory order under section 132(3) of the Income-tax Act, 1961 had been served on the bank, that the restraint order was allegedly breached, and that the locker operation by the assessee was supported by statements of bank officials and CCTV footage. Applying the settled principles governing quashing of criminal proceedings, the Court held that it could not assess the truthfulness or reliability of the allegations at that stage and that an FIR is not required to disclose every detail of the offence. The Court further held that quashing is an exception, to be exercised sparingly, and that where the FIR discloses a cognizable offence the investigation should not be interdicted.

Conclusion: The FIR disclosed a cognizable offence and no ground for quashing was made out. The application was dismissed.

Ratio Decidendi: At the stage of quashing, the FIR must be read as it is, and if its uncontroverted allegations disclose a cognizable offence, the High Court should not evaluate their truth or sufficiency or stifle investigation.

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