In Brief
The CBI appealed the quashing of an FIR against a Commissioner of Income Tax (and her spouse, a state MLA and minister) for allegedly possessing assets disproportionate to their known income. The High Court had quashed the FIR for non-compliance with the CBI Manual's requirement to conduct a Preliminary Enquiry. The Supreme Court held that while a Preliminary Enquiry may be desirable in corruption cases, it is not mandatory—if information discloses a cognizable offence, an FIR may be registered directly. The High Court wrongly conducted a detailed examination of documents and merits instead of simply checking if the FIR prima facie disclosed an offence. The Court set aside the High Court's judgment and allowed the investigation to proceed.
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