Pendency of Probate Proceedings does Not Bar FIR Alleging Forgery of Registered Will: Delhi High Court

The Delhi High Court refused to quash an FIR alleging forgery of a registered Will, holding that pending probate proceedings do not bar criminal investigation.

The Court said allegations of forgery and use of forged documents constitute independent criminal offences and cannot be stalled by civil proceedings examining the Will’s validity.

It observed that civil and criminal remedies operate in distinct spheres with different standards of proof.

The Court further held that at the quashing stage, it cannot assess evidence or conduct a mini-trial, and dismissed the petition seeking to halt the investigation.

[Babita Chopra v. State]