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Sudhir Bhargava & Ors. vs. State Govt. of NCT of Delhi and Anr.

Criminal Miscellaneous Case · 2026:DHC:7832Decided 15 Sept 2026New Delhi Bench
CRL.M.C. 1633/2025CNR: DLHC010120292025
Justice Madhu Jain

Background

The petitioners, a brother and his wife and son, sought quashing of a 2022 FIR filed by the brother's sister, alleging that their late parents' Wills and a family partnership deed had been forged to deprive her of her rightful inheritance in a family chemical business. The FIR had followed decades of related civil litigation over the same Wills, in which the sister's earlier challenges had been dismissed. Police had initially filed a closure report finding no offence, but the trial court directed further investigation, including forensic examination of the disputed documents.

Decision Breakdown

The High Court held that the mere existence of parallel civil litigation over the same documents does not bar criminal investigation into allegations of forgery, and that a closure report does not automatically end a case: a magistrate can direct further investigation when genuine gaps remain, such as the absence of any handwriting/forensic examination here. The Court found the trial court had validly exercised its power in ordering further investigation and declined to interfere, holding this was not a case where the FIR was so groundless that continuing it would amount to abuse of process. The petition was dismissed, though the Court clarified it made no finding on whether the documents were actually forged.

Lesson Learnt

Family property disputes that have already been through civil courts can still give rise to a legitimate criminal investigation for forgery, and a police closure report is not the final word: a magistrate can order fresh investigation, including forensic testing, if the earlier probe was incomplete.

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