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Supreme Court of India 2025-11-04 allowed

Sadiq B. Hanchinmani vs State of Karnataka & Ors

Bench: 2 — Ahsanuddin Amanullah, Pankaj Mithal

In Brief

A judicial document (Rent Agreement) was allegedly forged using a fake E-stamp paper in a property dispute case. When the complainant discovered the forgery through RTI verification, he filed a private complaint seeking investigation. The Magistrate ordered police investigation under Section 156(3) CrPC, but the High Court quashed the FIR, treating it as a civil matter. The Supreme Court held that procedural irregularities by the Magistrate are protected under Section 460(e) CrPC and do not vitiate proceedings when prima facie evidence of cognizable offences exists. The Court emphasized that forgery of judicial documents is serious criminal conduct, and the High Court cannot quash proceedings at inception stage based on civil overtones. The Court restored the FIR and directed investigation to proceed.

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Criminal Procedure Magistrate's Powers Investigation Forgery Judicial Documents High Court Inherent Powers Section 156(3) CrPC Section 482 CrPC Cognizable Offences E-stamp Fraud

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