Legal Review and Analysis of Sadiq B Hanchanmani vs The State of Karnataka & Ors 2025 INSC 1282

In-Short 

Case: Sadiq B. Hanchanmani vs The State of Karnataka & Ors. (2025 INSC 1282)

The Supreme Court held that the High Court should not have quashed the direction for a police investigation under Section 156(3) CrPC as the complaint and material on record prima facie disclosed cognizable offences of forgery and fabrication of documents. The Court restored the FIR, emphasizing that investigations should not be thwarted at the initial stage.

1. Heading of the Judgment

Case Name: Sadiq B. Hanchanmani vs The State of Karnataka & Ors.
Citation: 2025 INSC 1282
Court: Supreme Court of India
Bench: Hon'ble Mr. Justice Pankaj Mithal and Hon'ble Mr. Justice Ahsanuddin Amanullah

2. Related Laws and Sections

This judgment primarily deals with the following legal provisions:

• Code of Criminal Procedure, 1973 (CrPC):
  Section 156(3): Power of a Magistrate to order a police investigation into a cognizable offence.
  Section 482: Inherent powers of the High Court to prevent abuse of the process of any court or to secure the ends of justice.
  Section 460: Irregularities which do not vitiate proceedings.

• Indian Penal Code, 1860 (IPC):
  Sections 120B (Criminal Conspiracy), 201 (Causing disappearance of evidence), 419 (Cheating by personation), 420 (Cheating), 468 (Forgery for purpose of cheating), 471 (Using as genuine a forged document).

• Code of Civil Procedure, 1908 (CPC):
  Order XXXIX Rule 2-A: Consequence of disobedience or breach of injunction.
  Order XLI Rule 5: Stay of proceedings and execution of decree by the Appellate Court.

3. Basic Judgment Details

• Nature of Case: Criminal Appeals arising from Special Leave Petitions.

• Appellant: Sadiq B. Hanchanmani (Complainant)

• Respondents: The State of Karnataka & several private individuals (accused).

• Impugned Orders: The Appellant challenged two orders from the Karnataka High Court (Dharwad Bench):
  First Impugned Order (24.07.2019): Quashed the Judicial Magistrate's order directing investigation against some accused.
  Second Impugned Order (18.11.2021): Quashed the investigation against the remaining accused, extending the reasoning of the first order.

• Outcome: The Supreme Court allowed the appeals, set aside the High Court's orders, and restored the FIR for investigation.

4. Core Principle and Analysis of the Judgment

A. The Central Issue: Premature Quashing of Investigation

The core legal issue before the Supreme Court was whether the High Court was justified in quashing the Judicial Magistrate's order directing a police investigation under Section 156(3) of the CrPC at a nascent stage, especially when prima facie evidence of forgery and fabrication of documents was alleged.

The High Court had quashed the investigation primarily on two grounds:

1. The Magistrate used the word "further investigated," which the High Court misinterpreted as a direction for "further investigation" under Section 173(8) CrPC, which is permissible only after a report is filed. It held the Magistrate did not apply his judicial mind.

2. The civil suit regarding the property title had been dismissed, and the role of some accused in the alleged forgery was not clearly spelt out.

B. Supreme Court's Analysis and Reasoning

i. Scrutiny of the Alleged Forgery
The Supreme Court conducted a detailed analysis of the factual matrix. The turning point of the case was a Rent Agreement produced by the accused on an E-Stamp Paper before the High Court in a civil appeal to justify their possession. The Appellant's investigation revealed that this E-Stamp Paper was fake. The serial number on the stamp paper used for the Rent Agreement corresponded to a completely different document—a Sale Agreement between unrelated parties. Official communication from the Inspector General of Registration confirmed the E-Stamp was fake. The Court found this to be a strong prima facie indicator of the commission of cognizable offences like forgery and using forged documents as genuine.

ii. Clarification on Magistrate's Power under Section 156(3) CrPC
The Supreme Court strongly disapproved of the High Court's hyper-technical interpretation of the word "further." It held that a holistic reading of the Judicial Magistrate's order made it unequivocally clear that he was referring the complaint for investigation under Section 156(3) CrPC and not ordering "further investigation" under Section 173(8). The usage of the word "further" was inconsequential to the nature of the direction.

The Court cited the precedent in Madhao v. State of Maharashtra, (2013) 5 SCC 615, which holds that a Magistrate, upon receiving a complaint, has the discretion to forward it to the police for investigation under Section 156(3) if it discloses a cognizable offence and if doing so would be conducive to justice.

iii. Reiteration of Legal Principles on Quashing and Investigation
The judgment extensively relied on Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, (2021) 19 SCC 401, a three-judge bench decision, to underscore the following principles:

• At the stage of quashing an FIR, the court only has to see if the allegations disclose a cognizable offence.

• The court should not evaluate the merits of the allegations or thwart the investigation at the initial stage.

• The police have a statutory duty to investigate cognizable offences, and the High Court must be circumspect in staying such investigations, especially when facts are hazy and the investigation has just begun.

• A balance must be struck, but if a prima facie case exists, the investigation must be allowed to proceed.

The Supreme Court held that in this case, the material before the Magistrate was more than sufficient to disclose cognizable offences, warranting a full-fledged police investigation.

5. Final Outcome and Directions

The Supreme Court allowed the appeals and passed the following directions:

1. The First Impugned Order (24.07.2019) and the Second Impugned Order (18.11.2021) passed by the Karnataka High Court were set aside.

2. The FIR bearing Crime No.12 of 2018 registered at Khade Bazar Police Station, Belagavi, was restored.

3. The police were directed to investigate the case expeditiously and in accordance with the law.

4. It was clarified that the private parties (accused) are at liberty to present their defence during the investigation and before the court at the appropriate stage.

5. The observations made in this judgment are confined to the issue of quashing the investigation and shall not prejudice any pending civil or criminal proceedings between the parties.

6. (MCQs) Based on the Judgment

1. The Supreme Court in Sadiq B. Hanchanmani vs State of Karnataka (2025 INSC 1282) primarily set aside the High Court's order because?
a) The High Court had convicted the accused without a trial.
b) The High Court erroneously quashed an FIR at a nascent stage despite the existence of prima facie material disclosing cognizable offences.
c) The Supreme Court found that the civil suit had been decided in favor of the appellant.
d) The Magistrate had taken cognizance of the offence under Section 190 CrPC.

2. According to the judgment, which legal principle, as reiterated in Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, governs the High Court's power to quash an FIR?
a) The High Court must conduct a mini-trial to assess the credibility of evidence before quashing.
b) The High Court's role is to see if the allegations in the FIR disclose a cognizable offence, and if so, it should generally permit the investigation to proceed.
c) The High Court should always quash an FIR if a parallel civil suit is pending between the parties.
d) The High Court must quash an FIR if the accused is a woman.