1 2026:CGHC:10496-DB NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR CRMP No. 518 of 2026 1 - Azmat Khan S/o Hasmat Khan Aged About 39 Years R/o- 135, Dhantiya, Bareli, P.S.- Teoliya, District- Bareli (U.P.). 2 - Mohammad Nazir S/o Mohammad Sharif Aged About 40 Years R/o Ward No. 07, Shishgarhdehat, Tahsil- Mirganj, P.S.- Shishgarh, Bareli, District- Bareli (U.P.). 3 - Tafsir Ahmad S/o Layeek Ahmad Aged About 40 Years R/o Ward No. 14, P.S.- Shishgarh, Tahsil- Mirganj, District- Bareli (U.P.). ... Petitioner(s) versus 1 - State Of Chhattisgarh Through P.S. Kasdol, Now - P.S.- Lawan, District- Balodabazar-Bhatapara (C.G.) 2 - Parasram Ratre S/o Sukhram Aged About 61 Years R/o Mohatara, P.S. - Lawan, Kasdol, District- Balodabazar-Bhatapara (C.G.) ... Respondent(s) For Petitioner(s) : Mr.Rajbahadur Singh, Advocate For Respondent No.1-State : Mr.Saumya Rai, Deputy Government Advocate Hon'ble Shri Ramesh Sinha, Chief Justice Hon'ble Shri Ravindra Kumar Agrawal, Judge Order on Board BABLU RAJENDRA BHANARKAR Digitally signed by BABLU RAJENDRA BHANARKAR Date: 2026.03.02 10:23:17 +0530 2 Per Ramesh Sinha , Chief Justice 28.02.2026 1. Heard Mr.Rajbahadur Singh, learned counsel for the petitioners as well as Mr.Saumya Rai, learned Deputy Government Advocate appearing for respondent No.1/State. 2. The present petition has been filed by the petitioners seeking following relief(s): “1) To Quash the FIR no. 148/2019 registered by the police station- Kasdol (Now P.S.-Lawan), District Balodabazar-Bhatapara (C.G.). 2) To quash the entire Charge-sheet no. 143/2025, dated 30.05.2025 filed in connection with Crime no. 148/2019, under Section 370(3), 342, 374, 506, 34 of Indian Penal Code by Police Station Kasdol, Now- P.S. Lawan) District- Balodabazar- Bhatapara (C.G.). 3) To Quash the cognizance taken dated- 16/7/2025. cognizance taken by the learned Chief Judicial Magistrate, Balodabazar, District:- Balodabazar, Bhatapara (C.G.). 4) To quash the entire criminal proceeding of Session Case no. 120/2025 pending before the learned 3rd Add. Session Judge, Balodabazar, District- Balodabazar- Bhatapara (C.G.) and may set free the petitioners from aforesaid allegation. In the interest of justice.” 3. The prosecution case, in brief, is that on 05.03.2019, the complainant, Parasram Ratre, lodged a complaint at Police 3 Station Kasdol (now Police Station Lawan), District Baloda Bazar– Bhatapara (C.G.), alleging that in the year 2018, accused Vishnu Patre, a resident of village Pachpedi, Masturi, District Bilaspur (C.G.), approached the complainant and other villagers/labourers with an offer of employment in a bricks company, assuring them attractive wages. Acting upon such assurance, the complainant and other labourers accompanied the accused to village Sahbegpur, District Shahjahanpur (U.P.). It is alleged that after working for some time, the labourers were subjected to ill- treatment by the present petitioners and other co-accused persons. They were allegedly treated as bonded labourers, deprived of basic facilities, and were not permitted to return to their homes. 4. On the basis of the said complaint, Police Station Kasdol (now Police Station Lawan), District Baloda Bazar–Bhatapara (C.G.), registered FIR No. 148/2019 on 05.03.2019 against the present petitioners and other accused persons for offences punishable under Sections 370(3), 342, 374, 506, and 34 of the Indian Penal Code. 5. Upon completion of the investigation, the concerned police authorities filed a charge-sheet before the learned Chief Judicial Magistrate, Baloda Bazar, District Baloda Bazar–Bhatapara (C.G.). The case was registered as Criminal Case No. 2906/2025 and, vide committal order dated 29.09.2025, was committed to the 4 learned Trial Court. After receipt of the record, the learned Trial Court, Baloda Bazar, registered the case as Criminal Case No. 2006/2025 and took cognizance of the matter on 16.07.2026. Hence, this petition. 6. Learned counsel for the petitioners submits that the petitioners are innocent and have been falsely implicated in the present case. They have not committed any offence as alleged in the FIR, and the allegations are wholly misconceived and baseless. No prima facie case is made out against the petitioners for the offences punishable under Sections 370(3), 342, 374, 506 and 34 of the Indian Penal Code. The materials collected during investigation do not disclose their involvement in the commission of the alleged offences. He further submits that the petitioners are engaged in the business of brick manufacturing and have been running the same honestly and lawfully. It is submitted that the complainant and other labourers had received advance wages; however, they were not working properly and were frequently consuming liquor/alcohol during working hours. Owing to such conduct, disputes arose, which have subsequently been converted into false allegations against the petitioners. He also submits that the petitioners have always treated the labourers properly and have maintained a staff register recording the attendance of labourers and payment of wages. In view of such documentary records, it cannot be alleged that the complainant and other labourers were subjected to ill-treatment or were treated as bonded labourers. 5 The petitioners are bona fide businessmen conducting their business through a duly executed partnership deed and are holders of a valid GST registration certificate. He contended that the allegations levelled against the petitioners are entirely unfounded. It is further submitted that, considering the facts and circumstances of the case, this Court has been pleased to grant anticipatory bail to petitioner Nos. 1 and 2 in MCRCA No. 562/2025, and the learned Trial Court has granted anticipatory bail to petitioner No. 3 in MCRCA No. 447/2025. It is further submitted that an amicable compromise has already been arrived at between the parties. The complainant did not object to the grant of bail to the petitioners. In view of the compromise entered into between the parties, the continuation of the criminal proceedings arising out of the said FIR would be an abuse of the process of law and, therefore, the same deserves to be quashed. He further contended that the complainant has misused the judicial process by lodging a false case against the present petitioners, which clearly amounts to abuse of the process of law and the petitioners have already paid the entire wages due to the labourers. It is submitted that the contractor, Vishnu Patre, had received substantial amounts from the petitioners for disbursement of wages to the labourers. If any dispute remains regarding payment, the same is between the contractor and the labourers. It is further submitted that, as per the petitioners’ knowledge, the labourers have already approached the learned 6 Labour Court seeking payment of alleged remaining wages. As such, the petition deserves to be allowed. 7. Per contra, learned Deputy Government Advocate appearing for respondent No. 1/State opposes the submissions made on behalf of the petitioners and submits that the allegations in the FIR and the material collected during investigation clearly disclose the commission of cognizable and serious offences punishable under Sections 370(3), 342, 374, 506 and 34 of the Indian Penal Code. It is contended that the statements of the complainant and other labourers specifically indicate that they were induced to leave their native place on the false promise of employment and attractive wages and were thereafter subjected to exploitation, restraint, and coercion. The nature of allegations prima facie attracts the ingredients of human trafficking and forced labour, and therefore the contention that no case is made out against the petitioners is wholly misconceived. He further submits that the defence taken by the petitioners, namely that the labourers were paid advance wages and were irregular in their work due to consumption of liquor, is a matter of evidence and cannot be adjudicated at this stage. The existence of a staff register or GST registration certificate does not absolve the petitioners of criminal liability when there are specific allegations of illegal confinement and forced labour. Such documents, even if produced, are subject to proof during trial. 7 8. Learned Deputy Government Advocate also submits that the grant of anticipatory bail to the petitioners does not amount to an expression on the merits of the case and cannot be construed as a ground for quashing the proceedings. It is further contended that the offences alleged are serious in nature and have a societal impact; therefore, even if a compromise has been entered into between the parties, the same cannot by itself be a ground for quashing the FIR, particularly when the offences are non- compoundable and relate to exploitation of labourers. It is also submitted that the plea regarding payment of wages through the contractor, Vishnu Patre, and the pendency of proceedings before the Labour Court are separate and independent issues, which do not dilute the criminal allegations arising out of the FIR. The question as to whether the labourers were paid in full or whether any dispute remains is a matter to be examined during trial on the basis of evidence. In view of the aforesaid, learned Deputy Government Advocate submits that the petition is devoid of merit, involves disputed questions of fact, and therefore deserves to be dismissed. 9. We have heard learned counsel for the petitioners and learned Deputy Government Advocate for the State at length and perused the documents appended with petition. 10. The petitioners have invoked the inherent jurisdiction of this Court seeking quashment of the FIR and consequential criminal 8 proceedings on the grounds of false implication, absence of prima facie material, grant of anticipatory bail, and an alleged compromise between the parties. 11. At the outset, it is to be noted that the FIR contains specific allegations that the complainant and other labourers were induced to leave their native place on the assurance of employment with attractive wages and were thereafter allegedly subjected to exploitation, restraint and coercion. The investigation conducted by the police culminated in filing of a charge-sheet for offences punishable under Sections 370(3), 342, 374, 506 and 34 of the Indian Penal Code. The statements of witnesses recorded under Section 161 Cr.P.C., as reflected in the charge-sheet, prima facie disclose the essential ingredients of the aforesaid offences. 12. The contention of the petitioners that they are bona fide businessmen, that the labourers were paid advance wages, that proper registers were maintained, and that any dispute is essentially civil in nature arising out of payment of wages, are matters which pertain to defence. These submissions require appreciation of evidence and examination of the veracity of rival claims, which is within the exclusive domain of the trial Court. At this stage, this Court, while exercising jurisdiction under Section 482 Cr.P.C., (now Section 528 B.N.S.S.) cannot embark upon a detailed analysis of disputed questions of fact nor conduct a mini- trial to determine the truthfulness of the allegations. 9 13. With regard to the compromise allegedly arrived at between the parties, it is to be observed that the offences alleged include serious and non-compoundable offences under the Indian Penal Code, including those relating to human trafficking and forced labour. Such offences are not merely private disputes but have a serious societal impact. The inherent power of this Court cannot be exercised to stifle legitimate prosecution, particularly when the allegations, on their face, disclose commission of cognizable offences. The mere fact that the complainant may not be pressing the matter or has entered into a compromise would not, by itself, justify quashing of the proceedings in the facts and circumstances of the present case. 14. The plea that wages have already been paid through the contractor and that proceedings are pending before the Labour Court are also matters of evidence and do not negate the criminal allegations made in the FIR. Whether the labourers were fully paid, whether they were wrongfully restrained or compelled to work, and whether the petitioners shared common intention, are all issues which can only be adjudicated upon after the parties lead evidence before the competent trial Court. 15. This Court is conscious of the settled legal principles that the inherent power under Section 482 Cr.P.C. is to be exercised sparingly, with circumspection, and only in cases where the allegations do not disclose any offence or where continuation of 10 proceedings would amount to abuse of the process of law. In the present case, having examined the FIR and the material collected during investigation, this Court is unable to hold that no offence is made out or that the proceedings are manifestly attended with mala fides so as to warrant interference at this stage. 16. Accordingly, this Court is of the considered opinion that the petitioners have failed to establish any ground for quashment of the FIR or the consequential criminal proceedings. The petition, being devoid of merit, is hereby dismissed. No order as to costs. Sd/- Sd/- (Ravindra Kumar Agrawal) (Ramesh Sinha) Judge Chief Justice Bablu