In a hearing that saw detailed arguments and occasional tense exchanges, the Supreme Court on Tuesday set aside two Karnataka High Court orders that had earlier quashed an investigation into an alleged forged rent agreement used during a property dispute. The bench of Justice Pankaj Mithal and Justice Ahsanuddin Amanullah directed that the police investigation must continue, remarking that halting inquiries too early could “obstruct the course of justice.”
The matter revolves around a piece of property in Belagavi and an E-Stamp paper which the complainant insists was fabricated to mislead the civil court.
Background
Sadiq B. Hanchinmani, the complainant, has been fighting a long-standing civil dispute over ownership of the property. When renovation work allegedly began on the property despite a status-quo order from the High Court, Sadiq filed contempt proceedings.
During those proceedings, the opposite party produced a Rent Agreement dated May 20, 2013-printed on an E-Stamp paper-claiming the property had been let out before the court order, meaning no violation occurred.
Suspicion grew after Sadiq sought verification of the stamp paper. The E-Stamp record reportedly showed that the same serial number was actually used for a completely different Sale Agreement between two unrelated persons. A letter from the Karnataka Registration Department also indicated that the Rent Agreement stamp paper might indeed be fake.
Sadiq then approached the Magistrate Court, which ordered a police investigation. However, two separate Single Judge benches of the Karnataka High Court quashed the criminal proceedings, saying the Magistrate had not applied judicial mind.
Court’s Observations
The Supreme Court disagreed with the High Court’s approach.
The bench observed, “The allegations here are not mere civil disputes. The issue of a fake E-Stamp, if true, goes to the integrity of court processes.”
The judges underlined that the Rent Agreement was crucial to the earlier proceedings, and whether it was forged is a matter that requires thorough police investigation - not premature judicial dismissal.
The bench noted that the Magistrate had correctly used powers under Section 156(3) CrPC, which permits referring a complaint for investigation when the allegations indicate a possible cognizable offense.
Justice Amanullah said during the discussion, “When prima facie material exists, stopping investigation at the very threshold would be contrary to law. The police must be allowed to investigate.”
Decision
The Supreme Court restored the FIR registered at Khade Bazar Police Station and directed authorities to complete the investigation “expeditiously and in accordance with law.” The Court clarified that its observations should not influence the ongoing civil case or the final result of the criminal inquiry.
The case effectively returns to the investigation stage, where police will now collect evidence and examine the authenticity of the contested document. No costs were imposed.
Case Title: Sadiq B. Hanchinmani v. State of Karnataka & Others (2025 INSC 1282)
Case Type: Criminal Appeals arising from quashing of FIR
Court: Supreme Court of India
Bench: Justice Pankaj Mithal & Justice Ahsanuddin Amanullah
Appellant: Sadiq B. Hanchinmani (Complainant)
Respondents: State of Karnataka and private accused parties
Decision Date: 04 November 2025
