In Brief
A major automobile manufacturer challenged an FIR alleging fraud and misrepresentation in the sale of vehicles fitted with emission control defeat devices. The manufacturer argued the criminal complaint's substratum overlapped with parallel NGT proceedings. The Court dismissed the challenge, holding that overlapping subjects in different forums do not bar investigation, disputed factual matters cannot be examined in a quash petition, and courts cannot usurp police jurisdiction. The judgment reaffirmed that FIRs are quashed only in the rarest cases disclosing no cognizable offence. Protection against arrest until filing the investigation report was adequate protection.
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