Inherent powers and FIR quashing: High Court declined interference where cognizable offences were disclosed and investigation was still pending.

When an FIR discloses cognizable offences and investigation remains pending, the High Court should ordinarily not invoke inherent powers under Article 226 or Section 482 CrPC to quash the proceedings at the threshold. The Court reiterated that it should not conduct a merits enquiry into the truthfulness of the allegations while the police investigation is underway, especially where the complaint suggests misdeclaration of goods, absence of e-way bills, and possible forged documents. As no final report had been filed, interference was considered premature and quashing was declined.

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Issues: Whether the FIR and the ongoing investigation should be quashed in exercise of inherent powers under Article 226 of the Constitution of India and Section 482 of the Code of Criminal Procedure, 1973 when the allegations disclose cognizable offences and the investigation is still pending.

Analysis: The petition sought quashing of the FIR and consequential proceedings on the basis that the allegations were untenable and that the dispute was not fit for police investigation. The governing principles on exercise of inherent powers were applied, including the restraint required at the investigation stage and the settled position that the Court should not embark upon a merits enquiry into the truthfulness of the FIR when cognizable offences are disclosed. The allegations indicated misdeclaration of goods, absence of e-way bills and possible forged documents, and the investigation had not culminated in a final report. In these circumstances, the matter was found to be premature for interference.

Conclusion: Quashing was declined and the petitioners were not entitled to relief under Section 482 of the Code of Criminal Procedure, 1973.

Ratio Decidendi: Where the FIR discloses cognizable offences and investigation is underway, the High Court should ordinarily not quash the proceedings or interfere on merits at the threshold unless the case falls within exceptional categories warranting such intervention.

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