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2026 Supreme(Online)(SC) 1640

Prashant Kumar Mishra, N.V. Anjaria, JJ
Roma Ahuja – Appellant
Versus
State – Respondent


Advocates:
For the Appellants/Petitioners: Shivani Vij
For the Respondents: Rajkumar Bhaskar Thakare, Mukesh Kumar Maroria, Praveen Swarup

Table of Content
1. overview of fir filing, limitation bar, and judicial background. (Para 1 , 2)
2. limitation period begins at complaint filing, not cognizance. (Para 5 , 6)
3. duty of counsel to adhere to binding precedents. (Para 7 , 8 , 9)
4. quashing of fir reversed due to incorrect limitation computation. (Para 10 , 11)

N.V. ANJARIA, J.

Leave granted.

2. These two appeals arise out of common order dated 30.01.2025, passed by the High Court of Delhi in Crl. M.C. No. 1170 of 2017 and Crl. M.A. No. 7270 of 2016. Thereby the High Court allowed the petition filed by Respondent No. 2-the accused, under Articles 226 and 227 of the Constitution read with Section 482 of the Code of Criminal Signature Not Verified MINI Date: 2026.04.09 Reason:

1 2 Procedure, 1973 for quashing the First Information Report No. 121 of 2011.

2.1 The said FIR was in respect of the commission of offences under Sections 323 and 341 read with Section 34 of the Indian Penal Code, 1860 , at P.S. Moti Nagar, lodged by the appellant-complainant herein. The FIR came to be quashed on the ground that the charge-sheet was filed on 29.05.2012, which was after a period of one year and 20 days from the date of incident and there

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