Supreme Court restores FIR in fake e-stamp forgery case – Sadiq B. Hanchinmani v. State of Karnataka (2025).
SUPREME COURT RESTORES FIR IN FAKE E-STAMP CASE
CASE SUMMARY – In Sadiq B. Hanchinmani v. State of Karnataka & Ors. (2025 INSC 1282), the Supreme Court restored an FIR quashed by the Karnataka High Court concerning a forged rent agreement allegedly created using a fake e-stamp paper. The Magistrate had rightly invoked Section 156(3) CrPC, referring the complaint for police investigation. The Court held that the High Court erred by misinterpreting the Magistrate’s order and interfering prematurely. Stressing on proper investigation of cognizable offences, it directed the police to proceed lawfully and swiftly, reaffirming judicial restraint in quashing FIRs at nascent stages.
| ASPECTS | DETAILS |
| Case Title | Sadiq B. Hanchinmani vs. State of Karnataka & Ors. (2025 INSC 1282) |
| Introduction | The Supreme Court dealt with a criminal appeal challenging Karnataka High Court orders that quashed FIRs related to alleged forgery and fake e-stamp papers used in a rent agreement. |
| Factual Background | The appellant alleged that the respondents forged a rent agreement using a fake e-stamp paper to claim possession of a disputed property. Earlier civil suits and appeals between the same parties had dealt with ownership issues. |
| Legal Issues |
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| Applicable Law | |
| Analysis | The Court held that the JMFC rightly referred the matter for investigation as there was prima facie evidence of forgery. It criticized the High Court for misinterpreting “further investigation” and quashing proceedings prematurely. |
| Conclusion | The Supreme Court set aside the High Court’s orders and restored FIR No. 12/2018 for police investigation. |
| Current Scenario | The FIR stands reinstated, and police investigation is to proceed lawfully. The judgment clarifies judicial discretion under Section 156(3) CrPC. |
“A Magistrate’s referral for investigation under Section 156(3) CrPC cannot be faulted when prima facie evidence of forgery exists.”
SOURCE – SUPREME COURT OF INDIA
READ ALSO –
- Sections 156(3), 173(8), 460 CrPC;
- Sections 120B, 201, 419, 471, 468, 420 IPC;
- CPC Sections 151, Order XXXIX Rule 2A.
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