Inherent jurisdiction to quash criminal proceedings is not to be exercised for evaluating evidence or resolving factual disputes. Where allegations prima facie reveal cognizable offences, procedural errors in citing statutes do not invalidate investigations, and such matters should proceed to trial rather than being quashed as civil disputes.

1. The present petition has been filed seeking quashing of FIR No. 17 dated 28.10.2025, registered at the Economic Offences Wing, Bhubaneswar, Khordha, under Sections 318(4), 319(2), 338, 336(3), 340(2), 341(1) and 61(2) of the Bharatiya Nyaya Sanhita, 2023, insofar as it relates to the present Petitioner.

I. FACTUAL MATRIX OF THE CASE:

2. The brief facts of the case are as follows:

i. Opposite Party No. 3, namely World Venture Ltd., through its Accountant, lodged a written complaint before the Economic Offences Wing, Bhubaneswar, District Khordha on 28.10.2025 alleging commission of cognizable offences, pursuant to which FIR No. 17 of 2025 came to be registered under Sections 318(4), 319(2), 338, 336(3), 340(2), 341(1) and 61(2) of the Bharatiya Nyaya Sanhita, 2023.

ii. The prosecution case, as borne out from the FIR and materials on record, is that one Mahesh Singh introduced the present Petitioner to the complainant company, whereafter the Petitioner represented himself to be an employee of the State Bank of India and induced the complainant to purchase assets allegedly held by the bank at prices lower than the prevailing market value. Acting on such representations, the complainant company entered into multiple transactions for purchase of properties and transferred substantial amounts of money, aggregating to approximately Rs. 14,01,83,039/-, to an account purportedly shown to belong to an official of the State Bank of India. The payments were made in several instalments between November 2024 and October 2025 pursuant to purported sale agreements and sale certificates. It subsequently came to light that the said account did not belong to the State Bank of India but was, in fact, the personal account of the Petitioner. It is further alleged that the Petitioner impersonated a bank official, used forged seals and fabricated documents, and thereby induced the complainant to part with huge sums of money with dishonest intention from the inception.

iii. During the course of investigation, various documents including sale agreements, sale certificates and allotment letters were seized. It further came to light that the Petitioner had earlier been employed as a Sales Executive with SBI Cap Securities Ltd., Bhubaneswar, but was suspended on 22.12.2023 and subsequently terminated on 28.05.2024. Despite such termination, he allegedly continued to misrepresent himself as being associated with the bank.

iv. The Petitioner was arrested on 29.10.2025. The investigation also revealed his involvement in similar transactions with other individuals, resulting in financial loss to multiple persons, as well as the existence of prior criminal cases against him.

v. The present petition has been filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 seeking quashing of the aforesaid FIR, inter alia, on the grounds that the dispute is civil in nature and that the FIR has been registered by referring to provisions of the repealed Code of Criminal Procedure, 1973.

II. SUBMISSIONS ON BEHALF OF THE PETITIONER:

3. Learned counsel for the Petitioner made the following submissions in support of his contentions:

i. The Petitioner submitted that the complaint was made on 28.10.2025 and, on the very same day, without any application of mind or conducting a preliminary enquiry, the FIR was registered by the Economic Offences Wing. It was contended that in cases involving financial and economic disp