As per case facts, a petition was filed to quash an FIR and charges related to forgery and manipulation of a complainant's ACR (Annual Confidential Report) to obstruct his promotion. ... The petitioner, a public servant, was accused based on co-accused statements. He contended that he lacked motive and sanction under Section 197 Cr.P.C. was mandatory. The State argued sufficient evidence and that sanction was not needed for forgery. The question arose whether the FIR and proceedings should be quashed based on disputed facts and the necessity of sanction under Section 197 Cr.P.C. for fabricating official documents. Finally, the Court, referencing Supreme Court precedents, dismissed the petition, stating that disputed facts cannot be decided in quashing proceedings. It held that forging documents is not part of official duty, thus Section 197 Cr.P.C. sanction is not required, and there was grave suspicion for framing charges.