State represented by Inspector of Police, District Crime Branch, Salen, Tamil Nadu & ors., (2019) 14 SCC 568, the Hon’ble Supreme Court reiterated the earlier view that where an accused seeks quashing of the FIR invoking inherent jurisdiction of the High Court, it is wholly impermissible for the High Court to enter into the factual arena to adjudge the correctness of the allegation in the complaint. In M/s. Neeharika Infrastructure (Pvt.) Ltd. Vs. State of Maharashtra & ors., reported in AIR 2021 SC 1918, the Hon’ble Supreme Court elaborately considered the scope and extent of the powers under Section 482 Cr.P.C and held that the power of quashing should be exercised sparingly, with circumspection and in the rarest of rare cases, such standard not being confused with the norms formulated in the context of the death penalty. It was further observed that while examining the FIR/complaint, quashing of which is sought, the Court cannot embark upon an inquiry as to the reliability or genuineness or otherwise of the allegations made therein, but if the Court thinks fit, regard being had to the parameters of quashing and the self-restraint imposed by law, and more particularly, the parameters laid down by the Supreme Court in R.P.Kapur Vs. State of Punjab, (AIR 1960 SC 866) and State of Haryana & ors. Vs. Bhajan Lal & ors., {(1992) Supp (1) SCC 335}, the Court would have jurisdiction to quash the FIR/complaint.
