Naveen Kumar Sah v. State of Bihar - CrPC/BNSS - Quashing - Chargesheet Filed

Code of Criminal Procedure 1973 - Section 173, 482 : Bharatiya Nagarik Suraksha Sanhita - Section 528 - A petition to quash the FIR does not become infructuous on submission of a police report under Section 173(2) of the CrPC, but when a police report has been submitted, particularly when there is no stay on investigation, the Court must apply its mind to the materials submitted in support of the police report before taking a call whether the FIR and consequential proceedings should be quashed or not. [Context: The Supreme Court set aside a Patna High Court order that had quashed an FIR without considering a charge-sheet already filed by the Investigating Agency. ]