**Subject:** Criminal Law - Forgery [p_7][p_8]

**Acts Referred:** Code of Criminal Procedure, 1973 - Sections 195(1)(b)(ii), 482 [p_4][p_7][p_8]

**(A)** Allegation of forgery - High Court quashed criminal proceedings assuming civil litigation had not attained finality - Civil suits were actually disposed of on 09.04.2021, with OS No.21 of 2012 dismissed and OS No.154 of 2017 allowed - No bar under Section 195(1)(b)(ii) to examine criminal allegations of forgery committed before production of documents in court - Allegations pertained to forgery prior to filing in civil suit [p_3][p_4][p_6][p_7][p_8]

**(B)** Section 195(1)(b)(ii) does not bar FIR or private complaint for forgery of a document subsequently filed in civil court if the forgery occurred before its production therein - Interpretation should not shield forgers merely because the forged document was later filed in proceedings [p_7][p_8]

**Facts of the Case:** Appellant challenged High Court's quashing of criminal proceedings against respondents for filing forged documents (fraudulently obtained stamp paper and unregistered sale agreement) in civil suit - Civil suits disposed of on 09.04.2021, though appeals reportedly pending [p_3][p_4][p_6][p_8]

**Findings of Court:** High Court erred on assumption of non-finality of civil litigation and in holding no prosecution possible until civil finality - Bar under Section 195(1)(b)(ii) not attracted as forgery preceded sub-judice stage [p_7][p_8]

**Issues:** Whether High Court correctly quashed proceedings under Section 482 CrPC based on non-finality of civil litigation and bar under Section 195(1)(b)(ii) [p_4][p_7]

**Ratio Decidendi:** Criminal proceedings for forgery allowable even with documents filed in civil court, if offence committed prior to submission - High Court's order set aside [p_7][p_8]

**Result:** Appeals allowed; High Court order dated 06.10.2022 quashed and set aside - No observation on merits of pending cases [p_8][p_9]