The Supreme Court of India, in a judgment dated November 4, 2025, restored a First Information Report (FIR) that had been quashed by the Karnataka High Court. The apex court held that the Judicial Magistrate First Class (JMFC) was justified in ordering an investigation under Section 156(3) of the Code of Criminal Procedure (CrPC) based on a private complaint, as there was “enough material available to justify a full-fledged investigation” into allegations of forgery, specifically the use of a fake E-Stamp Paper in judicial proceedings.
The judgment was delivered by a bench of Justice Pankaj Mithal and Justice Ahsanuddin Amanullah in criminal appeals filed by the complainant, Sadiq B. Hanchinmani.
Background of the Case
The case originated from a private complaint (PCR No.1/2018) filed

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