State Of Bihar And Anr vs Md. Khalique And Anr

The Supreme Court held that the High Court erred in quashing the investigation under Sections 419, 467, 420, and 120B of the Indian Penal Code, as the FIR contained specific allegations of forgery and conspiracy involving government officials and private individuals. The Court emphasized that the power to quash criminal proceedings should be exercised sparingly and only when no prima facie case is made out. The Court reinstated the investigation, finding that the allegations were sufficient to disclose a cognizable offence under the relevant sections of the IPC.