FIR quashing in corruption cases requires exceptional grounds; courts must not assess probability, reliability, or genuineness at investigation stage.

In a disproportionate assets corruption case, FIR quashing at the investigation stage is justified only in exceptional circumstances; the Court must not test the allegations for reliability, genuineness, or probability and should interfere only where no material exists to create even a reasonable suspicion of a cognizable offence. The FIR here, read with the preliminary inquiry, disclosed a prima facie basis for investigation, and the High Court erred by conducting a mini-trial. Allegations of mala fides also failed because they were vague, unsupported by proper pleading, and not backed by impleadment of the person alleged to be biased. The FIR was therefore not liable to be quashed and investigation could proceed in accordance with law.

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Issues: (i) whether the High Court was justified in quashing the FIR at the investigation stage in a disproportionate assets case; (ii) whether the FIR was liable to be quashed on the ground of mala fides.

Issue (i): whether the High Court was justified in quashing the FIR at the investigation stage in a disproportionate assets case.

Analysis: The power to quash an FIR is to be exercised sparingly and with circumspection, and the Court cannot embark upon an enquiry into the reliability, genuineness, or probable truth of the allegations at the threshold. In a corruption case involving alleged illicit enrichment, the FIR need only disclose a basis for reasonable suspicion of a cognizable offence; exactitude of figures is a matter for investigation and not a precondition for registration. The materials in the FIR, read with the preliminary inquiry, disclosed a prima facie case warranting investigation, and the High Court erred by assessing the allegations on a probability-based and mini-trial approach.

Conclusion: The High Court was not justified in quashing the FIR on this ground.

Issue (ii): whether the FIR was liable to be quashed on the ground of mala fides.

Analysis: Allegations of mala fides must be specifically pleaded and supported by proper foundation. The pleadings were found to be vague and general, and the person against whom mala fides were alleged was not impleaded eo nomine. In corruption matters, the decisive factor is the material ultimately collected in investigation, and the mere presence of political overtones does not by itself justify quashing where the FIR otherwise discloses a cognizable offence. Exceptional interference is reserved for cases where there is no material at all and mala fides alone is the basis for investigation, which was not the position here.

Conclusion: The FIR was not liable to be quashed on the ground of mala fides.

Final Conclusion: The impugned judgment quashing the FIR could not be sustained, and the writ petitions were liable to be dismissed so that investigation could proceed in accordance with law.

Ratio Decidendi: In a disproportionate assets corruption case, an FIR may be quashed only in exceptional circumstances where it discloses no material giving rise to even a reasonable suspicion of cognizable offence, and the court must not test the allegations for probability, reliability, or genuineness at the stage of investigation.

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