Petition for Quashing of FIR

IN THE [high_court] CRIMINAL MISC. PETITION NO. ________ OF 20____ IN THE MATTER OF: [petitioner_name] [petitioner_address] ... PETITIONER VERSUS 1. STATE 2. [complainant_name] ... RESPONDENTS PETITION UNDER SECTION 528 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 FOR QUASHING OF FIR No. [fir_number] MOST RESPECTFULLY SHOWETH: 1. That FIR No. [fir_number] has been registered at Police Station [police_station] against the Petitioner for offences under [offences_alleged]. 2. FACTS AND BACKGROUND [facts] 3. GROUNDS FOR QUASHING [grounds_for_quashing] 4. FURTHER GROUNDS A. That the allegations made in the FIR, even if taken at their face value and accepted in their entirety, do not prima facie constitute any offence or make out a case against the Petitioner. B. That the allegations are absurd and inherently improbable, and on their basis no prudent person could ever reach a just conclusion that there is sufficient ground for proceeding against the Petitioner. C. That the dispute between the parties is essentially civil in nature, and has been given a criminal colour with the oblique motive of pressurising the Petitioner. D. That the proceedings have been instituted with malice and with an ulterior motive for wreaking vengeance on the Petitioner and to spite him for private and personal grudge. E. That no offence is disclosed against the Petitioner, and the continuation of the proceedings would amount to an abuse of the process of the court. F. That the continuance of the criminal proceedings would cause grave prejudice, harassment and irreparable injury to the reputation and liberty of the Petitioner. G. That the Petitioner craves leave to urge such further grounds at the hearing as may be advised. 5. That the Petitioner has not filed any other petition seeking the same relief before this or any other court. 6. That the Petitioner has approached this Hon'ble Court promptly and without delay. PRAYER It is therefore most respectfully prayed that this Hon'ble Court may be pleased to: (a) Quash FIR No. [fir_number] registered at Police Station [police_station], and all proceedings arising therefrom, in exercise of the inherent powers of this Hon'ble Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023; (b) Pending hearing and final disposal, stay all further proceedings pursuant to the said FIR, and direct that no coercive steps be taken against the Petitioner; (c) Pass such other orders as this Hon'ble Court may deem just and proper. AND FOR THIS ACT OF KINDNESS, THE PETITIONER SHALL EVER PRAY. Place: ______________ Date: [petition_date] [petitioner_name] PETITIONER Through ______________________ ADVOCATE FOR THE PETITIONER NOTE: Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 preserves the inherent powers of the High Court — the successor to Section 482 of the Code of Criminal Procedure, 1973 — to make such orders as may be necessary to give effect to any order, to prevent abuse of the process of any court, or otherwise to secure the ends of justice. Quashing is exercised sparingly and with circumspection. The High Court does not embark on an inquiry into the reliability or genuineness of the allegations at this stage. The petition must be supported by an affidavit and by a certified copy of the FIR.