Supreme Court Revives FIR Against Gram Panchayat Head: Key Takeaways

The Supreme Court of India recently delivered an important judgment in the case of D.B. Ravikumar vs G.S. Suresh & Anr., setting aside a High Court order that had quashed an FIR against a Gram Panchayat Adhyaksha (President). The judgment, delivered by Chief Justice Sanjiv Khanna and Justice Sanjay Kumar, reinforces the principle that investigations should not be prematurely scuttled, especially when the FIR discloses cognizable offences.

The case relates to FIR No. 158/2021 registered at Kanakapura Rural Police Station in Karnataka’s Ramanagara district. The FIR alleged offences under Sections 420 (cheating), 468 (forgery for purpose of cheating), 465 (forgery) and 471 (using as genuine a forged document) of the Indian Penal Code against G.S. Suresh, who held the position of Adhyaksha of the Grama Panchayat.

The Karnataka High Court had quashed the FIR primarily on the ground that the complainant (D.B. Ravikumar) sought to prosecute Suresh because of his official position. The Supreme Court found this reasoning untenable, observing: “The High Court could not have prematurely scuttled the entire investigation on the ground that the complainant/appellant, D.B. Ravikumar, sought to prosecute Respondent No. 1, G.S. Suresh, primarily because he held the position of Adhyaksha of the Grama Panchayat. This reasoning is untenable, particularly when the High Court itself acknowledged the presence of certain irregularities.”

Read also: https://judgmentlibrary.com/supreme-court-orders-murder-charges-in-honour-killing-case-key-details/

The apex court emphasized that once an FIR is registered and discloses cognizable offences, the allegations must be properly investigated. The bench noted: “Once the FIR is registered, the allegations made therein must be duly considered. Respondent no. 1, G.S. Suresh, is required to address these allegations during the course of the investigation. Therefore, as the FIR discloses the commission of an offence, the High Court ought not to have quashed it solely on the aforementioned ground.”

The Supreme Court allowed the appeal and set aside the High Court’s judgment, reviving the FIR. However, the bench clarified that its observations shouldn’t be construed as findings on the merits of the case. All contentions of both parties were left open to be raised during the investigation and trial.

This judgment serves as an important reminder about the limited scope of interference at the FIR stage. The Supreme Court has consistently held that courts should be cautious while exercising their powers to quash FIRs, especially when they disclose cognizable offences. The position or status of an accused cannot be grounds to short-circuit the investigative process, particularly when allegations of serious offences like forgery and cheating are involved.

Petitioner Name: D.B. Ravikumar.
Respondent Name: G.S. Suresh & Anr..
Judgment By: Justice SANJIV KHANNA, Justice SANJAY KUMAR.
Place Of Incident: Ramanagara, Karnataka.
Judgment Date: 17-04-2025.
Result: allowed.

Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!

Download Judgment: d.b.-ravikumar-vs-g.s.-suresh-&-anr.-supreme-court-of-india-judgment-dated-17-04-2025.pdf