Two petitioners, Pardeshi Ram Sonkar and Jagat Ram Sonkar, filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 before the Chhattisgarh High Court seeking to quash FIR No. 159/2023, the charge-sheet, and criminal proceedings registered against them under Sections 420 and 34 of the Indian Penal Code for alleged cheating in connection with a proposed sale of land for Rs. 50,00,000/-. The complainant, Mahendra Sachdev, alleged that he paid substantial earnest money but the petitioners failed to execute the sale deed, while the petitioners contended the dispute was purely civil/contractual in nature, there was no dishonest intention from inception, and the FIR was filed after an inordinate delay. The High Court, relying on the Supreme Court's decisions in State of Haryana v. Bhajan Lal, Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, and Pradeep Kumar Kesharwani v. State of Uttar Pradesh, held that the allegations in the FIR, taken at face value, prima facie disclosed cognizable offences and that disputed questions of fact could not be adjudicated in quashing proceedings. The Court found that the case did not fall within any of the categories warranting exercise of inherent jurisdiction to quash and accordingly declined to interfere with the criminal proceedings.