An accused named in an FIR usually asks one question first: can the High Court end this case now? This research paper answers that question from 177 reported judgments of the Supreme Court of Pakistan (44) and the Peshawar High Court (133), all taken from the Pakistan Law Site.

The main finding is that the law has moved. The Supreme Court began with a general bar on quashing during investigation (Ahmad Saeed, 1996 SCMR 186). It now draws a clear line: section 561-A Cr.P.C. reaches only proceedings pending in a court, while the FIR and the investigation can be reached, if at all, only under Article 199 of the Constitution, and only in exceptional cases (PLD 2023 SC 265; PLD 2025 SC 254).

When does the Peshawar High Court quash an FIR? When the police had no authority to register it, when a statutory bar on cognizance applies, or when the facts on the face of the FIR show that no offence exists.

When does it refuse? When the case turns on disputed facts, when a dispute looks civil but also discloses a cognizable offence, or when the plea can be taken later before the trial court under sections 249-A and 265-K Cr.P.C.

Practical points for the accused: read the FIR the way the High Court will; if registration was without authority, file under Article 199, not section 561-A; give your version to the investigating officer in writing; and after the challan, go to the trial court under 249-A or 265-K first.

Practical points for the complainant and the State: rely on the statutory duty to investigate under section 154, show that the issue is factual, and point out that civil and criminal proceedings can run together.

The full paper, with the case table and a practical guide for both sides, is free to download:
https://arbitratorandlaw.com/resources/research/5/file

For more research papers like this one, visit the Resources page:
https://arbitratorandlaw.com/resources

Adv. Syed Zeshan Hashmi, Advocate High Court
The Arbitrator & Law Associates, Opposite Prime Hospital, Ring Road, Peshawar | 0313-4859592