GST Invoices, Banking Channels and Tax Returns cannot Justify Quashing FIR at Investigation Stage: Chhattisgarh HC [Read Order]

The High Court of Chhattisgarh has held that a First Information Report (FIR) filed in an economic offence case cannot be quashed at the threshold by merely relying on Goods and Services Tax (GST) invoices, banking channel transactions and filed tax returns.

The facts follow the registration of a FIR on 27.05.2025 on the basis of a complaint by the Chief Executive Officer of Janpad Panchayat Sankargarh regarding large-scale financial irregularities in the Jila Sahakari Bank, Sankargarh/Kusmi Branch.

Consequently statutory audit and subsequent special audits were conducted which allegedly revealed material financial irregularities, involving suspicious transactions routed through multiple bank accounts.

It was further alleged that a certain portion of the amounts were transferred to accounts including that of the M/s Jamuna Alankar Mandir - a jewellery business run by the petitioner Navneet Soni @ Pintu.

The instant petition has been lodged seeking quashing of the FIR, charge-sheet and the order taking cognizance.

The petitioner, represented by Manoj Paranjape and Risabh Gupta contended that all transactions with the co-accused were genuine B2C jewellery transactions, all of which were supported by valid GST invState Of Chhattisgarh Through Station House Officer,oices, banking records including NEFT transfers and statutory tax filings.

It was contended that the provisions of section 420 of the Indian Penal Code does not stand as there was no proof of dishonest intention, wrongful gain and no material establishing conspiracy.

Saumya Rai, appearing for the State submitted that the investigation had revealed repeated high-value transfers to the petitioner’s firm from accounts found to be involved in financial irregularities. It was also stated that the petitioner;’s claims were factual in nature and required appreciation of evidence which could only be determined during trial.

The Division Bench comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal observed that the High Court shall not exercise its powers of quashment to conduct a mini-trial or examine the probative value of evidence collected during investigation.

Since the charge-sheet disclosed a prima facie case, the Court noted that economic offences involving public money are grave in nature.

At this juncture, the Court noted that the petitioner’s reliance on GST invoices, banking channels and tax returns, though relevant for defence, does not conclusively establish innocence at the investigation stage.

Affirming that the present case did not fall within the rarest of rare categories warranting interference, the High Court dismissed the petition and permitted the criminal proceedings to continue.

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