Allahabad HC Refuses to Quash Forgery FIR in QNet-Linked Fraud Case

The Allahabad High Court has declined to quash an FIR lodged against four individuals accused of forging documents to mislead investigators in a financial fraud case linked to the “QNet” business venture.

The bench of Justice Chandra Dhari Singh and Justice Lakshmi Kant Shukla stated that the criminal complaint disclosed distinct offences of forgery and fabrication, separate from an earlier cheating case involving the same parties.

Court dismissed the writ petition filed by Parul Budhraja and three others who had sought to quash a 2024 FIR registered at Police Station Link Road, Ghaziabad, under Sections 420, 467, 468, and 471 of the Indian Penal Code. The petitioners had argued that the impugned FIR was nothing more than a “second FIR” on identical facts already covered in a 2021 FIR.

The case originated from a complaint by Rishabh Agnihotri, who alleged that the accused were running a fraudulent online business syndicate under the brand ‘QNet’. Acting in concert, they allegedly induced his brother, Shubham Agnihotri, to invest Rs. 7.5 lakh in 2019 through false representations of lucrative returns from travel and health-related projects.

The fresh FIR, however, stemmed from allegations that the accused later fabricated a “Declaration” and “Distributor Application Form” bearing forged signatures of Rishabh, his mother Shobha, and his brother Shubham, along with a fake notarial seal. These documents were purportedly used during the investigation of the earlier case to obtain relief and mislead authorities. Notary Virendra Singh, whose seal and signature were allegedly forged, had categorically denied attesting any such documents in his written response to legal notices sent in 2023.

Challenging the FIR, the petitioners, through Advocate Mohit Kumar Shukla, argued that it was an abuse of law and motivated by personal vendetta. They claimed that Rishabh acted as a proxy for his brother Shubham, with whom petitioner Parul Budhraja had prior financial dealings and civil disputes. They cited the Supreme Court’s judgments in T.T. Antony v. State of Kerala and Arnab Goswami v. Union of India to argue that the Constitution prohibits multiple FIRs on the same set of facts.

The respondents, represented by Senior Advocate Anil Tiwari, assisted by Advocate Kabeer Tiwari, countered that the present FIR concerned fresh offences committed after the earlier case, involving distinct acts of forgery and use of false documents. The FIR, they said, was registered following a magistrate’s direction under Section 156(3) of the Criminal Procedure Code after the police failed to act on prior complaints.

After examining the material on record and legal precedents, the bench held that the test to determine whether a second FIR is maintainable depends on whether it concerns the same incident or a distinct one. Citing Anju Chaudhary v. State of U.P. and State of Rajasthan v. Surendra Singh Rathore (2025), court observed that a subsequent FIR is legally permissible if it discloses separate offences or new facts emerging after the first case.

The earlier FIR related to inducement and cheating in a financial investment, whereas the present one concerns the fabrication and use of forged documents in judicial proceedings. The two are separate in scope, nature, and period, the bench held.

Finding no grounds for interference under Article 226 of the Constitution, the High Court dismissed the petition and directed that the investigation shall continue in accordance with law, uninfluenced by its observations.

"At this preliminary stage of investigation, this Court is not inclined to embark upon a detailed appreciation of facts or evidence. The veracity of the allegations of forgery, fabrication, and use of false notarial seals is a matter for investigation and, if warranted, trial," court stated.

Case Title: Parul Budhraja And 3 Others vs State of UP and 3 Others

Order Date: October 30, 2025

Bench: Justice Chandra Dhari Singh and Justice Lakshmi Kant Shukla