Quashing of FIR at investigation stage refused where cognizable offences and official bribery allegations required continued police inquiry.

An FIR should not be quashed at the investigation stage where the allegations disclose cognizable offences and the investigation remains in progress. The allegations extended beyond GST evasion to cheating, criminal conspiracy and bribery involving public officials, and recovered diaries referred to payments to officials. Because the police investigation had not reached material completion, exercising inherent jurisdiction to terminate the proceedings would improperly interfere with the statutory power to investigate. The availability of a report under Section 173 of the Code of Criminal Procedure, 1973 was also relevant to the stage of consideration. The petition for quashing was therefore held premature and the FIR was not quashed.

---

---

Issues: Whether the FIR could be quashed at the investigation stage when the allegations disclosed cognizable offences and the investigation was still in progress.

Analysis: The allegations were not confined to alleged GST evasion alone and included assertions of cheating, criminal conspiracy, and bribery involving public officials. The Court noted that diaries had been recovered showing reference to payments to officials, and that the investigation was continuing. In such circumstances, the exercise of inherent jurisdiction to terminate the proceedings would interfere with the police power to investigate and would be unwarranted unless the matter had reached material completion. The availability of a statutory report under Section 173 of the Code of Criminal Procedure, 1973 was also relevant to the stage of consideration.

Conclusion: The petition for quashing was premature and the FIR was not quashed.

---