Delay in filing FIR cannot quash.
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In a significant ruling on April 30, 2025, the Supreme Court of India clarified that a delay in registering a First Information Report (FIR) for offences punishable with imprisonment exceeding three years cannot serve as a valid ground to quash the FIR. The Court emphasized that such delays should not be viewed in isolation but must be assessed in the context of the specific facts and circumstances of each case. The bench, comprising Justices Dipankar Datta and Manmohan, noted that the High Court had erroneously quashed the FIR, which involved serious allegations under Sections 467, 468, 471, 420, and 120B of the Indian Penal Code, all of which prescribe punishments exceeding three years. The Supreme Court reinstated the FIR, underscoring the importance of allowing the investigative process to proceed without premature judicial intervention .
This decision aligns with the Court’s previous stance that inherent powers under Section 482 of the Criminal Procedure Code should be exercised sparingly and only in exceptional circumstances. The Court reiterated that the mere pendency of civil proceedings or a delay in lodging an FIR does not automatically justify quashing a criminal complaint, especially when the allegations disclose the commission of a cognizable offence .
Legal experts view this ruling as a reaffirmation of the judiciary’s commitment to upholding the integrity of the criminal justice system, ensuring that serious allegations are thoroughly investigated and adjudicated on their merits, rather than being dismissed on procedural grounds.
Sources