Ajay Arya vs State Of Rajasthan on 16 July, 2026

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    Rajasthan High Court – Jodhpur

    Ajay Arya vs State Of Rajasthan on 16 July, 2026

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            HIGH COURT OF JUDICATURE FOR RAJASTHAN
                           AT JODHPUR
            S.B. Criminal Miscellaneous (Petition) No. 2087/2025
                          CNR: RJHC010253052025
                        URN: CRLMP / 3630U / 2025
    
    1.       Ajay Arya S/o Lajpat, Aged About 27 Years, R/o 24
             Ambika City Police Station Sadar Dist. Shriganganagar.
    2.       Shourabh Chawla S/o Ramesh Kumar, Aged About 35
             Years, R/o Chunaveda Dist. Shriganganagar.
    3.       Saloni Chawla W/o Shourabh Chawla, Aged About 30
             Years, R/o Chunaveda, Dist. Shriganganagar.
    4.       Karamjeet Singh S/o Malkeet Singh, Aged About 28
             Years, R/o Kaliya Dist. Shriganganagar.
                                                          ----Petitioners
                                    Versus
    1.       State Of Rajasthan, Through Pp
    2.       Subhas Chandra S/o Not Known, R/o Sho Ps Sadar Dist.
             Shriganganagar.
                                                        ----Respondents
                               Connected With
            S.B. Criminal Miscellaneous (Petition) No. 2478/2025
                          CNR: RJHC010291442025
                        URN: CRLMP / 4211U / 2025
    1.       Manish Yadav S/o Dev Raj Yadav, Aged About 30 Years,
             R/o Ward No. 13, 6 F Bada, Dist. Ganganagar.
    2.       Prmod Yadav S/o Devraj Yadav, Aged About 27 Years, R/o
             Chak 6F 2Nd 6F Dist. Sriganganagar.
    3.       Bhajanlal S/o Hariram, Aged About 31 Years, R/o Ward
             No. 01, Near B R Public School, Dist. Ganganagar.
    4.       Satpal S/o Prem Kumar, Aged About 38 Years, R/o
             Waryam Khera, Dist. Firozpur Punjab.
    5.       Rajindra Singh S/o Pram Kumar, Aged About 32 Years, R/
             o Waryam Khera, Dist. Firozpur Punjab.
    6.       Baljeet Singh S/o Gurcharan Singh, Aged About 49 Years,
             R/o Shergarh, Dist. Firozpur Punjab.
                                                          ----Petitioners
                                    Versus
    1.       State Of Rajasthan, Through Pp
    2.       Subhash Chandra S/o Unknown, Sho Ps Sadar Dist.
             Sriganganagar.
                                                        ----Respondents
            S.B. Criminal Miscellaneous (Petition) No. 4306/2025
                          CNR: RJHC010484122025
                        URN: CRLMP / 7474U / 2025
    1.       Lajpat S/o Sh. Chunnilal, Aged About 52 Years, R/o 24,
             Ambika City 2, Sri Ganganagar, Sadar Ganganagar,
             Ganganagar, Rajasthan.p
    2.       Deepak S/o Sh. Lajpat, Aged About 30 Years, R/o 24,
             Ambika City 2, Sri Ganganagar, Sadar Ganganagar,
             Ganganagar, Rajasthan.
    
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                                                                            ----Petitioners
                                Versus
    State Of Rajasthan, Through Public Prosecutor
                                                                          ----Respondent
    
    
    For Petitioner(s)              :     Mr. Madhav Vyas
                                         Mr. S.K. Bhati
    For Respondent(s)              :     Mr. Vikram Rajpurohit, PP
                                         Mr. Shiv Singh
    
    
    
          HON'BLE MR. JUSTICE BALJINDER SINGH SANDHU

    Order

    Reportable

    SPONSORED

    16/07/2026

    1. The present criminal miscellaneous petition has been filed

    under Section 528 of the Bharatiya Nagarik Suraksha Sanhita,

    2023 (for short, “BNSS”), seeking quashing of FIR No.46/2025

    registered at Police Station Sadar Ganganagar, District Sri

    Ganganagar for the offences under Sections 111(2)(b), 111(3),

    111(4), 111(6), 317(2), 317(5), 318(4) and 61(2)(b) of the

    Bharatiya Nyaya Sanhita, 2023 (for short, “BNS”), along with

    Sections 66-C and 66-D of the Information Technology Act, 2000.

    2. Learned counsel for the petitioners submits that the

    impugned FIR is wholly unsustainable in law, being a second FIR

    in respect of the very same transaction. It is contended that an

    earlier FIR bearing No.38/2025 had already been registered at

    Police Station Purani Abadi for the offences under Sections 420,

    406 and 120-B IPC on substantially the same allegations and

    therefore, registration of the present FIR No.46/2025 is

    impermissible. It is further submitted that the present FIR is

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    merely an offshoot of the investigation conducted in the earlier

    FIR and does not disclose any fresh or independent transaction

    warranting registration of a separate FIR.

    3. Learned counsel further submits that the alleged occurrence

    pertains to the year 2023, and therefore invocation of the

    provisions of the BNS, which came into force subsequently, is ex

    facie illegal. It is also contended that mere recovery of ATM cards,

    laptops, computers, mobile phones or other articles from the

    possession of the petitioners, even if accepted on its face value,

    does not satisfy the ingredients of organised crime punishable

    under Section 111 BNS. On these grounds, quashing of the

    impugned FIR and all consequential proceedings has been prayed

    for.

    4. Learned counsel for the petitioners has placed reliance upon

    the judgment of the Hon’ble Supreme Court in T.T. Antony v.

    State of Kerala reported in (2001) 6 SCC 181, contending

    that registration of a second FIR in respect of the same incident or

    transaction is impermissible in law and amounts to an abuse of

    the process of investigation.

    5. Learned Public Prosecutor has opposed the petition. The case

    diary has been produced before the Court along with the factual

    report concerning the investigation. Reply to the petition has also

    been filed by the State. The same are taken on record.

    6. Learned Public Prosecutor submits that the earlier FIR

    No.38/2025 was lodged at the instance of a private complainant

    alleging that he had been cheated of a substantial amount of

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    money, whereupon offences under Sections 420, 406 and 120-B

    IPC were registered. During investigation, however, it was found

    that the occurrence forming the subject matter of the said

    complaint had taken place outside the territorial jurisdiction of the

    concerned Police Station and accordingly a Final Report came to

    be submitted.

    7. It is submitted that the present FIR stands on an entirely

    different footing. During the course of investigation, a search was

    conducted at the premises of the petitioners and several articles,

    including cash, numerous ATM cards, laptops, rubber stamps,

    cheque books, computers, mobile phones and property-related

    documents, were recovered. During further investigation, various

    bank accounts and mobile numbers associated with the petitioners

    were allegedly found linked with a large number of cyber-fraud

    complaints.

    8. Learned Public Prosecutor submits that the material so

    discovered disclosed allegations extending far beyond the

    individual transaction forming the subject matter of FIR

    No.38/2025 and indicated the petitioners’ alleged involvement in

    organised cyber-fraud activities. It was in the backdrop of such

    material that the present FIR came to be registered. Thus,

    according to the State, the present FIR relates to distinct and

    substantially wider criminal activity and cannot be termed a

    second FIR in respect of the same transaction.

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    9. Heard learned counsel for the parties and perused the

    material available on record, including the case diary produced

    before the Court.

    10. The material collected during investigation prima facie

    reveals that the petitioners were allegedly engaged in Forex

    trading through their company, Cappmorefx. It is alleged that

    persons were induced to invest substantial amounts on the

    representation that such investments would yield high returns and

    substantial profits. The amounts so received were allegedly routed

    through different fake firms and bank accounts and thereafter

    withdrawn.

    11. The investigation further indicates allegations relating to

    transactions in virtual currency/USDT. The petitioners are alleged

    to have been engaged in purchase and sale of Forex/USDT

    through different persons and by using online platforms, including

    Telegram. The proceeds of the alleged fraudulent transactions

    were allegedly routed through cash transactions and different

    bank accounts and were thereafter utilised, inter alia, for

    acquisition of properties in the names of the petitioners and their

    family members.

    12. More significantly, according to the investigation, various

    bank accounts and mobile numbers associated with the petitioners

    were found linked with numerous cyber-fraud complaints. The

    material placed before the Court indicates allegations of victims

    having been cheated through different modes and methods. Apart

    from inducement of persons to invest substantial amounts under

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    the guise of Forex trading through Cappmorefx, allegations

    regarding cheating of unemployed persons on the pretext of

    providing employment and other fraudulent transactions have also

    surfaced during investigation. During the search conducted at the

    residential premises of the accused, cash, ATM cards, property

    documents and other articles were recovered. Proceedings under

    Section 107 BNSS have also been initiated in respect of properties

    alleged to have been acquired from the proceeds of crime.

    13. The first question which arises for consideration is whether

    FIR No.46/2025 is liable to be quashed merely because the

    material which led to its registration surfaced during investigation

    of the earlier FIR No.38/2025.

    14. The law in regard to registration of a second FIR is well

    settled. There cannot ordinarily be a second FIR in relation to the

    same incident, occurrence or transaction merely on the basis of

    further information received during investigation. The Court is

    required to examine whether the two FIRs relate to the same

    occurrence or to different incidents or transactions. Where the

    subsequent information merely relates to further material

    concerning the very same transaction, it is ordinarily required to

    be investigated as part of the first FIR. Conversely, where the

    subsequent information discloses a distinct incident or criminal

    activity which does not form part of the same transaction,

    registration of a separate FIR is not prohibited.

    15. The Hon’ble Apex Court in the case of State of Rajasthan

    versus Surendra Singh Rathore reported in 2025 INSC 248,

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    while considering its earlier decisions in T.T. Antony v. State of

    Kerala reported in (2001) 6 SCC 181, Anju Chaudhary v.

    State of U.P., (2013) 6 SCC 384, Kari Choudhary v. Sita

    Devi, (2002) 1 SCC 714, Upkar Singh v. Ved Prakash,

    (2004) 13 SCC 292, Babubhai v. State of Gujarat, (2010) 12

    SCC 254, and Nirmal Singh Kahlon v. State of Punjab,

    (2009) 1 SCC 441, has clearly held that where the subsequent

    information discloses a distinct incident or criminal activity, the

    scope and ambit of the two FIRs are different, or the subsequent

    FIR reveals a larger conspiracy, registration of the second FIR is

    legally permissible. The relevant observations contained in

    paragraphs 9 to 9.5 of the said judgment are reproduced

    hereunder:

    “9. From the above conspectus of judgments, inter alia, the
    following principles emerge regarding the permissibility of the
    registration of a second FIR:

    9.1 When the second FIR is counter-complaint or presents a rival
    version of a set of facts, in reference to which an earlier FIR
    already stands registered.

    9.2 When the ambit of the two FIRs is different even though they
    may arise from the same set of circumstances.
    9.3 When investigation and/or other avenues reveal the earlier FIR
    or set of facts to be part of a larger conspiracy.
    9.4 When investigation and/or persons related to the incident
    bring to the light hitherto unknown facts or circumstances.
    9.5 Where the incident is separate; offences are similar or
    different.”

    16. In the present case, FIR No.38/2025 arose out of an

    individual complaint alleging cheating of a particular complainant.

    The scope of the present FIR, however, is substantially different.

    The material collected during investigation prima facie discloses

    allegations concerning operation of several bank accounts, Forex/

    USDT transactions, linkage of bank accounts and mobile numbers

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    with numerous cyber-fraud complaints, inducement of several

    persons to make investments, other modes of alleged cheating

    and acquisition of properties from the alleged proceeds thereof.

    17. Thus, the nature and scope of the allegations forming the

    subject matter of the present FIR are prima facie materially wider

    and distinct from the individual transaction which formed the basis

    of FIR No.38/2025. The investigation revealed that the earlier FIR

    to be a part of a larger conspiracy regarding Cyber fraud. Mere

    circumstance that the material leading to registration of the

    present FIR surfaced during investigation of the earlier FIR would

    not, by itself, render the subsequent FIR impermissible. What is

    material is the nature of the criminal activity disclosed by such

    material and whether it constitutes part of the same transaction.

    18. Upon consideration of the allegations and the material

    presently available, this Court is unable to hold, at this stage, that

    both FIRs relate to one and the same transaction so as to render

    FIR No.46/2025 impermissible in law. The contention of the

    petitioners that the present FIR is liable to be quashed merely

    because it originated from material recovered during investigation

    of FIR No.38/2025 is, therefore, not acceptable.

    19. The next contention of learned counsel for the petitioners is

    that the allegations in the earlier FIR relate to the year 2023, and

    since the present FIR has arisen out of the investigation of that

    FIR, the provisions of the BNS cannot be invoked.

    20. The contention cannot be accepted at this stage. As noticed

    above, the present FIR is not confined to the transaction forming

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    the subject matter of the earlier FIR. During investigation, further

    material was recovered which prima facie disclosed allegations of

    wider and distinct criminal activities involving several bank

    accounts, cyber-fraud complaints and other transactions.

    Therefore, merely because such material came to light during

    investigation of an FIR relating to the year 2023 would not, by

    itself, make the provisions of the BNS inapplicable.

    21. The applicability of the BNS would depend upon when the

    acts constituting the offences alleged in the present FIR were

    committed. The same can be determined on the basis of the

    material collected during investigation. Thus, at this stage the

    present FIR cannot be quashed merely on the ground that the

    earlier FIR related to a transaction of the year 2023.

    22. So far as the applicability of Section 111 BNS is concerned,

    learned counsel for the petitioners contends that mere recovery of

    electronic devices, ATM cards, cheque books and other articles

    would not constitute an offence of organised crime.

    23. There can be no dispute that mere recovery of such articles,

    by itself, would not satisfy the ingredients of Section 111 BNS.

    However, the prosecution case is not based on the recoveries

    alone. The investigation has also revealed numerous bank

    accounts and mobile numbers allegedly linked with cyber-fraud

    complaints, inducement of several persons to make investments,

    Forex/USDT transactions, routing of the alleged proceeds through

    different accounts and acquisition of properties therefrom.

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    24. Whether the material collected during investigation

    ultimately satisfies all the ingredients of Section 111 BNS,

    including those relating to continuing unlawful activity, is a matter

    to be examined on completion of investigation. At this stage, the

    Court is not required to undertake a detailed examination of the

    evidence. In any case, the FIR cannot be quashed merely on the

    ground that a particular penal provision may ultimately not be

    attracted, when the allegations otherwise prima facie disclose

    cognizable offences requiring investigation.

    25. The principles governing the exercise of inherent powers for

    quashing criminal proceedings at the stage of investigation are no

    longer res integra.

    26. The Hon’ble Supreme Court in M/s Neeharika

    Infrastructure Pvt. Ltd. v. State of Maharashtra, (2021) 10

    SCC 118, after considering the entire jurisprudence on the

    subject, authoritatively summarised the governing principles in

    paragraph 80 of the judgment and held that where the allegations

    in the FIR and the material collected during investigation prima

    facie disclose the commission of a cognizable offence, the High

    Court ought not to embark upon an appreciation of the evidence

    or adjudicate the correctness of the allegations while exercising its

    inherent jurisdiction. Ordinarily, the investigation should be

    permitted to proceed unless the case falls within the well-

    recognised exceptional categories. The relevant observations are

    reproduced hereunder:-

    “(ii) The Court should not thwart any investigation into the
    cognizable offences;

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    (iv) The power of quashing should be exercised sparingly with
    circumspection, in the rarest of rare cases;

    (vii) Quashing of a complaint/FIR should be an exception rather
    than an ordinary rule;

    (x) Save in exceptional cases where non-interference would result
    in miscarriage of justice, the Courts and the judicial process should
    not interfere at the stage of investigation;

    (xii) The first information report is not an encyclopaedia and the
    police must be permitted to complete the investigation. It would be
    premature to pronounce the conclusion based on hazy facts that the
    complaint/FIR does not deserve to be investigated;

    (xiv) However, at the same time, if the Court thinks fit, regard
    being had to the parameters of quashing and the self-restraint
    imposed by law, more particularly the parameters laid down by this
    Court in the cases of R.P. Kapur and Bhajan Lal, the Court has
    jurisdiction to quash the FIR/complaint;

    (xv) When a prayer for quashing the FIR is made, the Court has
    only to consider whether the allegations disclose the commission of
    a cognizable offence. The Court is not required to consider the
    merits of the allegations or whether the allegations are likely to be
    proved.

    27. The Hon’ble Supreme Court has, inter alia, held that the

    Court should not thwart investigation into cognizable offences, and

    the Court is principally concerned with whether the allegations

    disclose commission of a cognizable offence and is not required to

    adjudicate whether such allegations would ultimately result in

    conviction.

    28. Tested on the aforesaid principles, the material presently

    available on record cannot be said to disclose a case where

    continuation of investigation would amount to abuse of the

    process of law. The allegations and the material collected during

    investigation prima facie disclose cognizable offences. The

    questions concerning the precise nature of individual transactions,

    the role attributable to each accused, applicability of particular

    penal provisions and sufficiency of the material to establish their

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    ingredients are matters which cannot appropriately be subjected

    to a detailed evidentiary examination while exercising jurisdiction

    under Section 528 BNSS at the stage when investigation is in

    progress.

    29. It is equally well settled that the FIR is not expected to

    contain an exhaustive account of the prosecution case and the

    investigating agency must ordinarily be permitted to investigate

    the allegations and collect evidence. This Court, while exercising

    inherent jurisdiction, cannot conduct a mini-trial or undertake a

    meticulous appreciation of the material with a view to determine

    whether the allegations would ultimately result in conviction.

    30. In view of the foregoing discussion, this Court finds that the

    present FIR cannot, at this stage, be termed an impermissible

    second FIR relating to the same transaction merely because the

    material leading to its registration surfaced during investigation of

    the earlier FIR. The material on record prima facie discloses

    allegations of a substantially wider and distinct nature requiring

    investigation.

    31. It is clarified that the observations made herein are only for

    deciding the present petition for quashing of the FIR and shall not

    be treated as a final finding regarding the applicability of any

    particular penal provision, including Section 111 BNS. The

    investigating agency and the Court concerned shall consider the

    applicability of the relevant provisions in accordance with law and

    on the basis of the material collected during investigation, without

    being influenced by the observations made in this order.

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    32. Consequently, no case for exercise of inherent jurisdiction

    under Section 528 BNSS for quashing FIR No.46/2025 is made

    out.

    33. Accordingly, the Criminal Miscellaneous Petition is dismissed.

    34. All pending applications, if any, also stand disposed of.

    (BALJINDER SINGH SANDHU),J)

    229-231-/Hanuman Ram/365

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