ORDER : (PER: HON'BLE MR. JUSTICE SACHIN SHANKAR MAGADUM) These writ petitions, though filed separately, are interconnected and are therefore taken up together for final disposal. 2. W.P. No.22218/2025 is filed by Accused No.1 seeking quashing of FIR in Crime No.453/2025. 3. W.P. No.3923/2025 is filed by Accused Nos.2 to 4, who are subsequent purchasers of the disputed lands, seeking quashing of FIR in Crime No.52/2025. 4. W.P. No.16266/2025 is filed by the second respondent/de facto complainant seeking transfer of investigation in Crime No.52/2025 to the Central Bureau of Investigation (CBI). 5. BRIEF FACTUAL BACKGROUND: The genesis of the present batch of petitions can be traced to the death of one K. Raghunath, who allegedly died by suicide on 04.05.2019 in a guest house. The said Raghunath was the husband of Smt. Manjula, the second respondent herein. 6. Accused No.1 asserts that the deceased had executed a registered will dated 20.04.2018, registered on 24.04.2019, bequeathing his immovable properties in favour of Accused No.1. It is further contended that Accused No.1 was a Director in entities of the D.A. Adikeshavalu Group, engaged in real-estate ventures, and that due to statutory restrictions on agricultural land purchase, certain acquisitions were routed in the name of the deceased under several Memoranda of Understanding dated 17.05.2005. SEQUENCE OF PRIOR PROCEEDINGS: 7. Upon the demise of K. Raghunath, his widow lodged multiple complaints alleging forgery and fabrication of the will and related documents. The following table presents the details of the FIRs and related proceedings: EARLIER COURT ORDERS & CBI INVESTIGATION: 8. This Court in W.P. No.4333/2021 (order dated 28.03.2021) had permitted constitution of a Special Investigation Team (SIT). Subsequently, on dissatisfaction with progress, the de facto complainant approached this Court again in W.P. No.7784/2022, resulting in an order dated 03.09.2022 directing transfer of investigation in Crime Nos.89/2020, 148/2020 and 7/2021 to the CBI. 9. Aggrieved, Accused No.1 and others approached the Hon’ble Supreme Court in SLP Nos.10449/2022 and 10515/2022. The Apex Court, affirming the order of this Court, directed as follows: “18. Reverting back to the facts of the present case, the deceased was closely associated with DKA, a member of Parliament and Chairman of Temple Sri Venkateswara Swamy Temple (Tirumala Tirupathi Devasthanam). The deceased, a close confidant of DKA, was a successful realtor and had huge assets in and around Bangalore. Reverting back to the facts of the present case, the deceased was closely associated with DKA, a member of Parliament and Chairman of Temple Sri Venkateswara Swamy Temple (Tirumala Tirupathi Devasthanam). The deceased, a close confidant of DKA, was a successful realtor and had huge assets in and around Bangalore. His mysterious death was preceded by execution of two different Wills, one in favour of his wife/respondent no. 1 and the other in favour of respondent No. 12 which was registered after his controversial death. There are civil proceedings relating to mutation and declaration of title as well as the allegations concerning forgery of stamp papers. The learned Magistrate while directing further investigation and the High Court, under the impugned order, has highlighted the glaring defects in the investigation which we have avoided to reiterate so that it does not influence the CBI investigation. However, the fact remains that the truth surrendering the death of K. Raghunath needs to be settled after a complete and fair investigation by the CBI which, in the facts and circumstances of the present case, has rightly been directed by the High Court. 19. We, accordingly, affirm the order of the High Court and dismiss the appeals. The CBI shall conduct the investigation within a period of 08 months and the State of Karnataka shall render all possible assistance to the CBI to make a fair investigation into the crime. The entire papers shall be handed over by the concerned police to the CBI within 15 days. If the CBI proceeds to file chargesheet, the same shall be submitted before the jurisdictional CBI Court in the State of Karnataka.” 10. Thus, the CBI investigation presently covers the alleged murder, forgery of wills, antedated stamp papers, and related transactions forming the foundational chain of title. CIVIL LITIGATION & HONOURABLE SUPREME COURT INTERIM STAY: 11. Parallelly, Accused No.1 instituted O.S. No.246/2020 seeking declaration of title based on the will dated 20.04.2018. The plaint was rejected under Order VII Rule 11(a)&(d) CPC by the Trial Court on 30.10.2023. 12. This Court, in RFA No.2216/2023, by order dated 22.02.2024, set aside the rejection and restored the suit. However, the Hon’ble Supreme Court, in SLP (C) No.9724/2024, by order dated 08.04.2025, stayed the operation of the High Court’s restoration order. Thus, the civil dispute regarding the will and ownership of properties is sub-judice before the Hon’ble Supreme Court. 12. This Court, in RFA No.2216/2023, by order dated 22.02.2024, set aside the rejection and restored the suit. However, the Hon’ble Supreme Court, in SLP (C) No.9724/2024, by order dated 08.04.2025, stayed the operation of the High Court’s restoration order. Thus, the civil dispute regarding the will and ownership of properties is sub-judice before the Hon’ble Supreme Court. SUBSEQUENT ALIENATION AND NEW FIRs: 13. While the appeal order in RFA No.2216/2023 stood operative, Accused No.1 executed registered sale deeds dated 14.11.2024 alienating the following properties to Accused Nos.2–4: i. Sy.No.92/6 – 36 guntas ii. Sy.No.92/5A – 1 acre 8 guntas 14. The subsequent purchasers claim to be bona fide purchasers for value, having verified the registered will, revenue records, and encumbrance certificates before purchase. It is these alienations which led to registration of Crime No.52/2025 and Crime No.453/2025 alleging cheating, forgery, impersonation, and fabrication of revenue records. RIVAL CONTENTIONS: Arguments of A1 (W.P. No.22218/2025): 15. Learned Senior Counsel Sri. C.H. Jadav submitted that the de facto complainant and her son have already set the criminal law in motion by lodging complaints that culminated in Crime Nos.89/2020, 148/2020, and 7/2021 — all of which are under CBI investigation. 16. Therefore, registration of fresh FIRs on identical facts amounts to misuse of police machinery and multiplicity of proceedings, contrary to law laid down by the Hon’ble Apex Court in T.T. Antony v. State of Kerala (2001) 6 SCC 181 . 17. He contended that the alienations effected by Accused No.1 were during pendency of civil proceedings and at a time when there was no injunction or restraint order. At best, the transactions would remain subject to the outcome of pending proceedings before the Supreme Court, and do not constitute criminality. Arguments of A2–A4 (W.P. No.3923/2025): 18. Learned Counsel appearing for accused Nos.2 to 4, has argued that the petitioners are subsequent purchasers for valuable consideration after due diligence. They are not connected to any alleged murder, forgery, or conspiracy. Even if the allegations are accepted at face value, no ingredients of forgery, cheating, or impersonation are made out against them. 19. Therefore, continuation of the proceedings in Crime No.52/2025 is a clear abuse of process of law. To substantiate his arguments learned counsel for the petitioners has relied on the following judgments: 1. Sardool Singh and Anr v. Smt. Nasib Kaur 1987 (Supp) SCC 146 . 2. 19. Therefore, continuation of the proceedings in Crime No.52/2025 is a clear abuse of process of law. To substantiate his arguments learned counsel for the petitioners has relied on the following judgments: 1. Sardool Singh and Anr v. Smt. Nasib Kaur 1987 (Supp) SCC 146 . 2. M. Srikanth v. State of Telangana and Anr- (2019) 10 SCC 373 . 3. Urmila Devi and Ors v. Balram and Anr- 2025 INSC 915 - Crl. Appl.No. 3300 of 2025. 4. Rikhab Birani & anr. v. State of Uttar Pradesh and anr ( 2025 INSC 512 ). 5. Om Prakash Ambadkar v. The state of Maharashtra & ors (2015 INSC 139). Arguments of De facto Complainant (W.P. No.16266/2025): 20. The learned Senior counsel for the second respondent contends that the transactions of 2024 are intrinsically connected to the original conspiracy and hence the new crimes must also be handed over to the CBI to ensure a comprehensive probe. 21. It is further submitted that Accused No.1 is an influential person with political links, and fair investigation cannot be expected at the hands of local police. To substantiate his arguments learned counsel for the complainant has relied on the following judgments: 1. State of West Bengal and Ors v. Committee for Protection of Democratic Rights, West Bengal and Ors- (2010) 3 SCC 571 . 2. Sri. C. N. Govindaraju and anr v. State of Karnataka and anr (WP.No.30657/2024). 3. Ramachandraiah & anr v. M. Manjula & Ors. 2025 INSC 556 22. Heard the learned Senior Counsel appearing for the petitioner/accused No.1, counsel appearing for petitioners/accused Nos.2 to 4 and learned Senior Counsel appearing for second respondent. The following points would arise for consideration: i. Whether registration of Crime Nos.52/2025 and 453/2025 constitutes a fresh cause of action and warrants investigation by the CBI ? ii. Whether subsequent alienations effected by Accused No.1 during pendency of civil proceedings amount to new an offence of cheating or forgery warranting fresh criminal investigation? iii. Whether the request to entrust Crime Nos.52/2025 and 453/2025 to the CBI merits acceptance, particularly in view of the Honourable Supreme Court’s staying of High court’s order restoring plaint on file? iv. Whether proceedings pending in Crime Nos.52/2025 and 453/2025 are liable to be quashed? Findings on Point Nos (i) and (ii)– Multiplicity of FIRs and Civil Nature of Transactions: 23. iv. Whether proceedings pending in Crime Nos.52/2025 and 453/2025 are liable to be quashed? Findings on Point Nos (i) and (ii)– Multiplicity of FIRs and Civil Nature of Transactions: 23. This Court finds substance in the submissions advanced by learned Senior counsel appearing for accused No.1 and learned counsel appearing for accused Nos.2 to 4. The core allegations regarding forgery of the will, MOUs, and title documents already form the subject of CBI investigation pursuant to orders in W.P. No.7784/2022 and the Supreme Court’s confirmation in SLP Nos.10449/2022 & 10515/2022. 24. The new FIRs (Crime Nos.52/2025 & 453/2025) merely arise out of subsequent sale transactions flowing from the same chain of title. The subject properties are those covered under the will of 2018, is sub-judice before the Hon’ble Supreme Court and is subject matter of investigation by CBI. 25. Where a civil title dispute is pending adjudication before the highest court, any transfer pendente lite would, at best, attract the doctrine of lis pendens (Section 52, TPA), and the purchasers’ rights remain subject to the outcome of the civil proceedings. It does not, however, give rise to fresh criminal liability, particularly where the foundational allegation of forgery is already being probed by the CBI. It becomes necessary to advert to the comprehensive suit filed by accused No.1 in OS No.246/2020. It does not, however, give rise to fresh criminal liability, particularly where the foundational allegation of forgery is already being probed by the CBI. It becomes necessary to advert to the comprehensive suit filed by accused No.1 in OS No.246/2020. The prayer in plaint is extracted which reads as under: “ WHEREFORE, the plaintiff most respectfully prays that this Hon'ble Court be pleased to:- a) Grant the decree of declaration, declaring that the plaintiff is the owner in possession of the suit schedule properties in terms of the will dated 20-4- 2018 executed by deceased K Raghunath and subsequently got registered by executor vide Document No.BYP-3-00098/2019-20,in book No.III and stored in CD No. BYPD529, dated 31-12-2019 in the file of Senior Sub-Registrar, Byatarayanapura, Bengaluru.; b) Grant the decree of declaration, declaring that the mistakes crepted in schedule of the will dated 20-4-2018 executed by K Raghunath subsequently got registered by executor vide Document No. BYP-3-00098/2019-20,in book No.III and stored in CD No. BYPD529, dated 31-12-2019 in the file of Senior Sub-Registrar, Byatarayanapura, Bengaluru and permitted to be rectified said will as sought for herein below: (i) In the schedule of Will in Item A Land comprising in Sy.No.274/1 of Avathi Village, Devanahalli Taluk, Bengaluru rural district, measuring 0-23 guntas to be inserted as one of the item of the property; (ii) In the schedule of Will at Sl No.01 of Item-A extent of the land comprising in Sy. No.268, to be rectified as 0-25 guntas instead of lacre-01guntas. (iii) In the schedule of Will at Sl No.1 of Item-A Land in Sy.No.267 of Avathi Village measuring 2 acre 06 guntas to be rectified as 2 acre 23 guntas; (iv) In the schedule of Will at Sl No.2 of Item-A the land bearing Sy.No.28/4 measuring 0-27 was shown as Avathi Village, same has to be corrected by showing the name of the village Dasarahalli as against Avathi; (v) In the schedule of will at Sl No.6 of Item-A Instead of Land in Sy.No.271/1 measuring 0-36 guntas of Avathi Village, Devanahalli Taluk, shown as Sy.No.272/1 by mistake; (vi) In schedule of Will at Sl No.03, Item No.4 of Item-B the property shown by an extent of 3.00 acres of Bullahalli village, Devanahalli Taluk Sy.No. to be add as Sy.No.121. (vii) In the schedule of Will at Sl No.2 of Item-C measurement has to be rectified as of 0-09 guntas in instead 0.14 guntas; c) Grant the decree of perpetual injunction restraining the defendants, their agents, servants or anybody claiming under them permanently from interfering with the lawful and peaceful possession of the plaintiff over the suit schedule properties; d) Pass such other order or decree or direction as this Hon'ble Court deem it fit and proper in the facts and circumstances of the case and decree the suit as prayed for with costs, in the ends of justice and equity.” 26. Records also reveal that Hon’ble Supreme Court has stayed the order passed by this Court in RFA No.2216/2023, wherein this Court reversed the order of the court of first instance rejecting plaint. This court order in above said appeal restored the plaint filed in OS No.246/2020, but however the Hon’ble Supreme Court has stayed the order of this Court restoring plaint on file and therefore matter completely seized before the Hon’ble Supreme Court. The order of the Hon’ble Supreme Court staying the order of restoration of plaint is relevant and the same is extracted, which reads as under: “1. Issue notice. 2. In addition, dasti service is permitted. 3. In the meanwhile, the restored proceedings shall be kept on hold until further orders.” 27. Hence, the registration of fresh FIRs on identical facts constitutes abuse of process and is barred by the ratio laid down by the Hon’ble Apex Court in T.T. Antony v. State of Kerala (2001) 6 SCC 181 , which holds that once an FIR has been registered and investigation commenced on a particular transaction, a second FIR on the same facts is impermissible. Accordingly, point Nos.(i) and (ii) are answered in the ‘Negative’. Finding on Point No. (iii)– CBI Transfer of Subsequent FIRs: 28. The CBI’s jurisdiction is confined to the offences and facts entrusted to it by judicial order namely, the death of K. Raghunath and the alleged fabrication of the will and MOUs. 29. It is trite that a direction for transfer of investigation to the CBI is an extraordinary measure, to be invoked sparingly, cautiously and only to secure the ends of justice in exceptional situations where the ordinary process is demonstrably inadequate. 29. It is trite that a direction for transfer of investigation to the CBI is an extraordinary measure, to be invoked sparingly, cautiously and only to secure the ends of justice in exceptional situations where the ordinary process is demonstrably inadequate. The Hon’ble Supreme Court has consistently held that the power under Articles 32/226 to entrust investigation to the CBI is not to be exercised as a matter of routine. 30. It is now well settled that referral of investigation to the Central Bureau of Investigation constitutes an extraordinary jurisdictional recourse and not an ordinary incident of judicial review. The Hon’ble Supreme Court in State of West Bengal v. Committee for Protection of Democratic Rights [ (2010) 3 SCC 571 , paras 68–70] held in unmistakable terms that though constitutional courts possess the power under Articles 32 and 226 to direct such transfer, the same must be exercised sparingly, cautiously and in exceptional circumstances, where the Court finds that the normal investigative process has been subverted or rendered ineffective. The Hon’ble Supreme Court emphasized that such entrustment is an exception to the federal scheme, and that routine transfers would erode the autonomy of the State police system. The principle was further crystallized in K.V. Rajendran v. CBI [ (2013) 12 SCC 480 , paras 13–15], where the Hon’ble Supreme Court emphasised that a CBI probe may be directed only in rare and exceptional cases involving either (i) a reasonable apprehension of bias or lack of credibility in the local investigation, or (ii) a complex or high-level conspiracy having inter-State ramifications, such that only a central agency can effectively investigate. In Pooja Pal v. Union of India [ (2016) 3 SCC 135 , paras 82–84], the Hon’ble Apex Court explained that the test is whether the facts disclose compelling circumstances that justify deviation from the ordinary investigative process, the object being to preserve public confidence in the fairness of inquiry rather than to satisfy an individual litigant. Similarly, in Secretary, Minor Irrigation & Rural Engineering Services, U.P. v. Sahngoo Ram Arya [ (2002) 5 SCC 521 , paras 5–7], the Hon’ble Supreme Court cautioned that mere allegations or suspicions against the State police are insufficient; there must be substantive material showing a credible failure or collusion before such extraordinary direction can issue. 31. Similarly, in Secretary, Minor Irrigation & Rural Engineering Services, U.P. v. Sahngoo Ram Arya [ (2002) 5 SCC 521 , paras 5–7], the Hon’ble Supreme Court cautioned that mere allegations or suspicions against the State police are insufficient; there must be substantive material showing a credible failure or collusion before such extraordinary direction can issue. 31. Applying these principles to the case at hand, this Court finds no circumstance warranting further expansion of the CBI’s mandate. The foundational allegations namely, the alleged murder of K. Raghunath, the Will dated 20.04.2018, and the four MOUs dated 17.05.2005 have already been entrusted to and are under active investigation by the CBI pursuant to orders passed by this Court in W.P. No. 7784/2022, duly affirmed by the Hon’ble Supreme Court in SLP Nos. 10449/2022 and 10515/2022. The present complaints in Crime Nos. 52/2025 and 453/2025 merely concern subsequent alienations effected by Accused No. 1 during pendency of civil proceedings, which are incidental civil consequences of the disputed Will and form part of a chain already under scrutiny. No fresh material, systemic bias, or investigative failure has been demonstrated so as to attract the “rare and exceptional” threshold contemplated in the above authorities. Once the central agency is seized of the core allegations and the civil title dispute is sub-judice before the Hon’ble Supreme Court, there is neither necessity nor justification to multiply investigative forums. Consequently, the prayer to further extend the CBI investigation to cover the later alienations must fail, being inconsistent with the settled law governing such extraordinary referrals. 32. The subsequent alienations by Accused No.1 in November, 2024 were effected after this Court restored the suit in RFA No.2216/2023 (later stayed by the Supreme Court). Since the Hon’ble Apex Court is seized of the civil lis concerning ownership, any direction to extend CBI investigation into these post-litigation transactions would amount to indirect interference with proceedings pending before the Supreme Court. 33. Moreover, whether the alienations are void or valid pendente lite is a civil consequence, not a criminal one. The question of entrusting such transactions to CBI does not arise when the underlying allegations of forgery are already being investigated by CBI; and the civil effect of the alienations is within the Supreme Court’s domain. Accordingly, the prayer for CBI transfer in W.P. No.16266/2025 deserves rejection. For the foregoing reasons, point No.(iii) is answered in the ‘Negative’. The question of entrusting such transactions to CBI does not arise when the underlying allegations of forgery are already being investigated by CBI; and the civil effect of the alienations is within the Supreme Court’s domain. Accordingly, the prayer for CBI transfer in W.P. No.16266/2025 deserves rejection. For the foregoing reasons, point No.(iii) is answered in the ‘Negative’. Finding on point No. (iv): 34. The fulcrum of the entire dispute concerns the alleged murder of Sri K. Raghunath, the genuineness of the Will dated 20.04.2018, and the alleged fabrication of four MOUs dated 17.05.2005. 35. These very allegations form the subject-matter of investigation entrusted to the Central Bureau of Investigation pursuant to the orders of this Court in W.P. No. 7784/2022, which have been affirmed by the Hon’ble Supreme Court in SLP Nos. 10449/2022 and 10515/2022. 36. The CBI has thus been authorised to investigate the core transaction from which all incidental consequences including later transfers and alienations flow. Once the central agency is seized of the principal allegations and the investigation is at an advanced stage, permitting the State police to independently examine the very same allegations through parallel FIRs amounts to splitting up a single cause of action into multiple criminal proceedings, which is impermissible in law. 37. This Court is of the considered opinion that the continuation of criminal proceedings in Crime Nos.52/2025 and 453/2025 cannot be sustained in law, as the very foundation of the allegations forming the basis for registration of these FIRs is already the subject matter of a comprehensive investigation being conducted by the Central Bureau of Investigation pursuant to the orders passed in W.P. No.7784/2022, which orders have been affirmed in unequivocal terms by the Hon’ble Supreme Court in SLP Nos.10449/2022 and 10515/2022. The allegations sought to be projected in the present FIRs do not disclose any fresh act of deceit, forgery or impersonation; rather, they arise solely as a consequence of subsequent alienations effected by Accused No.1 on 14.11.2024, which in turn trace their origin entirely to the very Will dated 20.04.2018 and the MOUs dated 17.05.2005 that are already under the scrutiny of the CBI. Once the central agency has been entrusted with examining the genuineness of the Will and MOUs, any attempt to initiate parallel or overlapping investigative processes before the jurisdictional police in respect of subsequent transactions flowing from the same chain of title would inevitably result in multiplicity of proceedings, conflicting investigative outcomes, and a clear abuse of the criminal justice machinery. The law declared by the Hon’ble Apex Court in T.T. Antony v. State of Kerala (2001) 6 SCC 181 squarely prohibits the registration of successive FIRs premised on the same set of facts or different versions of the same allegations, and the present FIRs, on a plain reading, amount to an impermissible second attempt to reopen an issue already entrusted to an investigating agency by judicial order. 38. Viewed from another angle, the alienations executed by Accused No.1 are transactions pendente-lite, effected during the pendency of civil proceedings wherein the validity of the Will and the competing claims of title are in issue. These alienations attract, at best, the doctrine of lis pendens under Section 52 of the Transfer of Property Act, 1882, by which any transfer made during litigation remains subject to the final outcome of such proceedings. The legal effect of such transfers is civil in character and falls squarely within the province of the civil court; such transfers do not, by themselves, constitute the offences of cheating, forgery or impersonation. The question whether these alienations are void, voidable, or otherwise affected by pendency of the suit is an adjudicatory matter now lying exclusively before the Hon’ble Supreme Court, which is seized of the civil lis after the restoration of the plaint in RFA No.2216/2023. Any parallel criminal investigation into the implications of these alienations would amount to indirect interference with proceedings pending before the Apex Court and would undermine the hierarchical discipline that the law insists upon when the highest constitutional forum is seized of the substantive dispute. 39. Furthermore, this Court finds that no new material or circumstance has been placed on record to suggest that any independent criminality transpired in 2024 that is distinct from the alleged fabrication of the Will and MOUs already being investigated by the CBI. The subsequent transactions are merely consequences of the same disputed title; therefore, they cannot furnish a fresh cause of action to invoke the criminal law once again. The subsequent transactions are merely consequences of the same disputed title; therefore, they cannot furnish a fresh cause of action to invoke the criminal law once again. Allowing the police to proceed with the investigation in Crime Nos.52/2025 and 453/2025 would create two parallel streams of investigation one by the CBI on the core allegations and another by the State police on the derivative civil consequences an outcome that is neither legally permissible nor practically tenable. The appropriate and lawful course is to permit the CBI to complete its mandate with respect to the genuineness of the testamentary documents, after which the civil rights of the parties will be determined by the Hon’ble Supreme Court; until then, any superadded criminal investigation only serves to multiply proceedings and prejudice the fair resolution of the dispute. 40. In this background, the present FIRs, being nothing but a restatement of allegations already in issue and already examined by the CBI, amount to an abuse of process and cannot be allowed to continue. The foundational dispute namely, the alleged forgery of the Will and MOUs is firmly within the investigative domain of the CBI. The civil consequences of subsequent transfers are pending adjudication before the Hon’ble Supreme Court. The criminal proceedings in Crime Nos.52/2025 and 453/2025 are therefore liable to be quashed in order to prevent multiplicity of proceedings, avoid conflicting findings, and uphold the integrity of the judicial process. 41. A further significant aspect that cannot be overlooked is that the purchasers arrayed as Accused Nos.2 to 4 are, in law, pendente-lite purchasers, having derived their rights through Accused No.1, who claims under the Will of late K. Raghunath. Their purchase is not independent, nor is it based on any fraudulent misrepresentation made by themselves to the complainant or any authority. They merely stand in the shoes of their vendor, and their rights rise or fall with the title of Accused No.1, whose suit seeking declaration of title on the basis of the very Will of Raghunath is now squarely pending consideration before the Hon’ble Supreme Court in SLP No.9724/2024. When the root of title is under judicial examination before the highest court, a transferee pendente lite cannot be fastened with criminal liability for cheating or forgery when they have not fabricated any document, nor have they projected themselves as deriving title through the complainant or the deceased Raghunath. When the root of title is under judicial examination before the highest court, a transferee pendente lite cannot be fastened with criminal liability for cheating or forgery when they have not fabricated any document, nor have they projected themselves as deriving title through the complainant or the deceased Raghunath. Their title is entirely derivative and flows solely from Accused No.1. The mere act of purchasing property during pendency of litigation, even with notice of the dispute, does not constitute the offences of cheating, impersonation, or forgery under the Penal Code. At best, their rights remain subject to the outcome of the civil proceedings, as mandated by Section 52 of the Transfer of Property Act. To criminally prosecute pendente lite purchasers for acts that are purely civil consequences of a disputed title would be wholly unwarranted and would convert a civil dispute pending before the Hon’ble Apex Court into a collateral criminal proceeding. Such a course is inconsistent with settled jurisprudence and would amount to misuse of the criminal process. 42. In view of the foregoing discussion, and having regard to the fact that the foundational allegations pertaining to the alleged fabrication of the Will dated 20.04.2018 and the MOUs dated 17.05.2005 are already under investigation by the Central Bureau of Investigation pursuant to the orders passed in W.P. No.7784/2022 (affirmed by the Hon’ble Supreme Court in SLP Nos.10449/2022 & 10515/2022), and further noting that the civil dispute concerning declaration of title under the said Will is presently seized of by the Hon’ble Apex Court in SLP No.9724/2024. For the foregoing reasons, this Court proceeds to answer point No.(iv) in the ‘affirmative’. 43. CONCLUSION: i. The continuation of investigation in Crime Nos.52/2025 and 453/2025, in so far as it pertains to alleged cheating, forgery, or impersonation arising from the sale transactions dated 14.11.2024, amounts to multiplicity of proceedings and abuse of process. ii. The foundation of the dispute namely, the alleged forgery of the will and MOUs is already under CBI investigation, and the civil title dispute is pending before the Hon’ble Supreme Court. iii. The alienations by Accused No.1 were executed when no restraining order existed, and their validity is subject to the Supreme Court’s decision in the pending matter. iv. Consequently, there exists no justification to extend CBI investigation to the subsequent transactions. 44. iii. The alienations by Accused No.1 were executed when no restraining order existed, and their validity is subject to the Supreme Court’s decision in the pending matter. iv. Consequently, there exists no justification to extend CBI investigation to the subsequent transactions. 44. In view of the foregoing reasons, this Court proceeds to pass the following: ORDER (i) W.P. No.22218/2025 and W.P No.22200/2025 filed by Accused No.1, and W.P. No.3923/2025, filed by Accused Nos.2 to 4, are hereby allowed. ii) In consequence, the proceedings in Crime No.453/2025 and Crime No.52/2025, pending before the jurisdictional police, and arising out of subsequent alienations that are derivative of the very title now under examination by the CBI and sub-judice before the Hon’ble Supreme Court, are hereby quashed. iii) W.P. No.16266/2025 and W.P No.25802/2025 filed by the de facto complainant seeking further transfer or expansion of investigation to the CBI, is dismissed, it being unnecessary and impermissible to widen the scope of investigation when the core allegations are already within the mandate of the CBI and the civil rights of the parties are concurrently under adjudication before the Hon’ble Apex Court in SLP No.9724/2024 and further this Court has already quashed the proceedings in Crime Nos.453/2025 and 52/2025. iv) All pending interlocutory applications, if any, stand disposed of.