In Brief
The Respondent's mother sought to transfer land property in her name through revenue proceedings, while the Respondent later sought declaration of ownership and filed separate appeals. Documents were submitted in these proceedings, leading to accusations of forgery. A High Court judgment had quashed the FIR against the Respondent for forgery offences, finding that preliminary inquiry under Section 340 of the CrPC was mandatory. The Supreme Court, encountering conflicting decisions of Bench precedents on whether Section 340 requires mandatory preliminary inquiry and hearing before filing a complaint under Section 195, referred the matter to a larger Bench for authoritative resolution of these procedural questions.</summary_100>
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