Section 482 CrPC quashing refused where FIR disclosed prima facie forgery, impersonation and disputed documents requiring investigation.

Inherent powers under Section 482 CrPC should not be used to quash an FIR where the allegations disclose a prima facie cognizable offence and no Bhajan Lal exception is made out. Allegations of forgery, impersonation, unauthorized access to an email account, and use of a forged resignation letter and Form DIR-12 required investigation, and the truth of the disputed signatures and documents could not be decided at the threshold. A plea of mala fides was found insufficient to stop the criminal process, so the proceeding was allowed to continue.

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Issues: Whether the criminal proceeding arising out of the FIR was liable to be quashed in exercise of inherent powers under Section 482 of the Code of Criminal Procedure, 1973.

Analysis: The allegations disclosed a prima facie case of forgery, impersonation, unauthorized access to the complainant's email account, and use of a forged resignation letter and Form DIR-12. The offences alleged were cognizable, and the matter did not fall within any of the recognized categories warranting quashing under the Bhajan Lal principles. The Court held that the truthfulness of the disputed signatures and documents was a matter for investigation, and it was not appropriate to short-circuit the criminal process at the threshold. The plea of mala fides was also found insufficient to justify interference.

Conclusion: The criminal proceeding was not liable to be quashed and was directed to continue.

Ratio Decidendi: Inherent power under Section 482 of the Code of Criminal Procedure, 1973 should not be exercised to quash a criminal proceeding where the FIR discloses a prima facie cognizable offence and none of the exceptional grounds for interference are made out.

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