As per case facts, an FIR was registered against the petitioner, a Notary Public, and others for allegedly preparing fake documents for a stolen vehicle. The petitioner was later implicated ... during investigation. The petitioner sought to quash the FIR, arguing that no criminal proceedings could be initiated without a specific written complaint from an authorized government officer under Section 13 of the Notaries Act. The question arose whether criminal proceedings against a Notary Public for official acts require a prior complaint from an authorized Central or State Government officer. Finally, the Supreme Court's principles, as applied by the High Court, affirmed that such proceedings are impermissible without the specified written complaint, leading to the quashing of the FIR and subsequent proceedings against the petitioner.