K. Rajalakshmi v. The State Of Tamilnadu Rep. Inspector Of Police
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 03.06.2026
CORAM:
THE HONOURABLE MR. JUSTICE G.K.ILANTHIRAIYAN Crl.
OP .No.
14081 of 20 26 and Crl.MP.No.8988 of 2026 K.Rajalakshmi ... Petitioner Vs.
1.The State of Tamil nadu rep.
Inspector of Police, Vigilance and Anti-Corruption (City Special Unit-III), Alandur, Chennai 600 016 2.G.Vimala 3.N.Sumathra ... Respondents Prayer: Criminal Original Petition filed under Section 528 of BNSS praying to call for the records on the file of the 1st respondent police in FIR crime No.01/AC/2026/CC-11 dated 12.02.2026 and quash the same. For Petitioner : Mr.S.Selvathirumurugan For Respondents For R1 : Mr.R.Ganesh Kumar, Counsel for Government of Tamil Nadu (Criminal Side)
ORDER
This criminal original petition has been filed praying to quash the proceedings in FIR crime No.01/AC/2026/CC-11 dated 12.02.2026 on the file of the 1st respondent police.
2.
The case of the Prosecution is that the petitioner entered the service as Woman Sub-Inspector of Police on 16.04.1999. After getting promoted as Inspector of Police, she has been continuously working in the sensitive places only within the Chennai City since 2010 with many adverse notices and hence by considering her working period in the sensitive places was taken into account as check period from 01.06.2017 to 30.06.2025 for computing her illegal earnings. Assets that stood to the credit of the petitioner at the beginning of the check period as on 01.06.2017 is Rs.3,64,310.90/- Value of assets as that stood to the credit of the petitioner at end of the check period as on 30.06.2025 is Rs.4,62,06,529.10/-. Income earned by the petitioner during the check period is Rs.1,45,80,000/-.
Expenditure incurred by the petitioner during the check period is Rs.2,25,98,000/-. Likely savings is Rs.80,18,000/-. Thus the value of assets of the petitioner during the check period from 01.06.2017 to 30.06.2025 is Rs.5,42,24,529/- (as Percentage 372%) which is disproportionate to her known sources of income. Reliable information discloses the prima-facie case against the petitioner that during the period from 01.06.2017 to 30.06.2025 by corrupt and illegal means had acquired moveable and immovable properties to the tune of Rs.
of income. Hence, after getting permission from the Director, Vigilance & Anti-Corruption, Chennai, a case was registered in Vigilance & AntiCorruption, Chennai City-II Detachment Cr.No.01/AC/2026/CC-II under Sections 13(2), r/w 13(1)(e) of Prevention of Corruption Act, 1988 for the period from 01.06.2017 to 25.07.2018 and under Sections 13(2) r/w 13(1) (b) of the Prevention of Corruption Act, 1988 as amended by the Prevention of Corruption (Amendment) Act, 2018 for the period from 26.07.2018 to 30.06.2025 on 12.02.2026 at 16.00 hrs against the petitioner. Aggrieved by the FIR, this criminal original petition has been filed by the accused.
3.
The learned counsel for the petitioner would submit that there is absolutely no material available to substantiate the allegation that the petitioner had acquired moveable and immoveable properties to the tune of Rs.5,42,24,529/-. He further submits that the second respondent, on suo motu, registered the FIR with malafide intention. 4.
On perusal of records, it is revealed that there are specific allegations in the FIR to make out a prima facie case to register FIR in crime No.01/AC/2026/CC-11 for the offences under Sections (2), r/w 13(1)(e) of Prevention of Corruption Act, 1988 and under Sections 13(2)
r/w 13(1)(b) of the Prevention of Corruption Act, 1988. This Court repeatedly held that FIR is not an encyclopedia to contain all the materials. That apart, FIR cannot contain all documents and wherever information received by the second respondent, according to the said information and if on verification and also preliminary enquiry found that there are prima facie material available to register FIR, subsequently FIR is registered. Therefore, the grounds raised by the petitioner cannot be considered to quash the FIR on its threshold. 5.
The Hon'ble Supreme Court of India, in the judgment reported in 2019 (14) SCC 350 in the case of Sau. Kamal Shivaji Pokarnekar vs. The State of Maharashtra & ors., (Crl.A.No.255 of 2019 dated 12.02.2019), held that the learned Magistrate while taking cognizance and summoning, is required to apply his judicial mind only with the view to taking cognizance of the offence whether a prima facie case has been made out for summoning the accused person. The learned Magistrate is not required to evaluate the merits of the materials or evidence in support of the complaint, because the Magistrate must not undertake the exercise to find out whether the materials would lead to conviction or not. Only in a case where the complaint does not disclose any offence or is frivolous, vexatious or oppressive, the complaint/FIR
can be taken for consideration for quashment. If the allegations set out in the complaint do not constitute the offence of which cognizance has been taken by Magistrate, it can be considered for quashment. Therefore, it is not necessary that a meticulous analysis of the case should be done before the trial to find out whether the case would end in conviction or acquittal. If it appears on a reading of the complaint and consideration of the allegations therein, in the light of the statement made on oath that the ingredients of the offence are disclosed, there would be no justification to interfere. At the initial stage of issuance of process, it is no open to the Court to stifle the proceedings by entering into the merits of the contentions made on behalf of the accused. Therefore, the criminal complaint cannot be quashed only on the ground that the allegations made therein appear to be of a civil nature. If the ingredients of the offence alleged against the accused are prima facie made out in the complaint, the criminal proceeding shall not be interdicted. 6.
Further the Hon'ble Supreme Court of India issued directions in the judgment reported in 2021 SCC Online SC 315 in the case of M/s.Neeharika Infrastructure Pvt. Ltd., Vs. State of Maharashtra & ors., as follows :- "23. ....................
vi) Criminal proceedings ought not to be scuttled at the initial stage;
vii) Quashing of a complaint/FIR should be an exception rather than an ordinary rule;
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xii) The first information report is not an encyclopaedia which must disclose all facts and details relating to the offence reported. Therefore, when the investigation by the police is in progress, the court should not go into the merits of the allegations in the FIR. Police must be permitted to complete the investigation. It would be premature to pronounce the conclusion based on hazy facts that the complaint/FIR does not deserve to be investigated or that it amounts to abuse of process of law. After investigation, if the investigating officer finds that there is no substance in the application made by the complainant, the investigating officer may file an appropriate report/summary before the learned Magistrate which may be considered by the learned Magistrate in accordance with the known procedure;
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xv) When a prayer for quashing the FIR is made by the alleged accused and the court when it exercises the power under Section 482 Cr.P.C., only has to consider whether the allegations in the FIR disclose commission of a cognizable offence or not. The court is not required to consider on merits whether or not the merits of the allegations make out a cognizable offence and the court
has to permit the investigating agency/police to investigate the allegations in the FIR; ......."
7.
Therefore, this Court is not inclined to quash the First Information Report. Accordingly, this Criminal Original Petition stands dismissed. Consequently, connected miscellaneous petition is closed. 03.06.2026 Index : Yes/No : Yes/No Speaking/non-speaking order lok To 1.The State of Tamil nadu rep.
Inspector of Police, Vigilance and Anti-Corruption (City Special Unit-III), Alandur, Chennai 600 016 2.The Public Prosecutor, High Court of Madras
G.K.ILANTHIRAIYAN, J.
lok 03.06.2026