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2026 DAILYLAW 20106 (CHH)

X Y Z v. STATE OF CHHATTISGARH

CRMP/1347/2026 · 2026-05-13

Shri Ravindra Kumar Agrawal

body2026

Judgment text

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1 2026:CGHC:22835-DB NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR CRMP No. 3567 of 2025 1 - Bhagwat Chandra S/o Shyam Lal Chandra Aged About 20 Years R/o Village Khairakala, Police Station And Tahsil Dabhara, District Sakti C.G. 2 - Narendra Chandra S/o Shyam Lal Chandra Aged About 24 Years R/o Village Khairakala, Police Station And Tahsil Dabhara, District Sakti C.G. --- Petitioner(s) versus 1 - State Of Chhattisgarh Through Station House Officer, Police Station Dabhara, District Sakti C.G. 2 - X Y Z (Description Of The Prosecutrix/ Complainant Is In The Closed Envelop). --- Respondent(s) For Petitioner(s) : Mr. Ishwar Jaiswal, Advocate For Respondent No.1/State : Shri Shaleen Singh Baghel, Govt. Advocate For Respondent No.2 : Mr. Tapan Chandra, Advocate 2 CRMP No. 1347 of 2026 1 - X Y Z Nill ---Petitioner(s) Versus 1 - State Of Chhattisgarh Through The Superintendent Of Police, Sakti, District- Sakti (C.G.) 2 - Station House Officer, P.S. Dabhara, District- Sakti (C.G.) 3 - A B C, Nill --- Respondent(s) For Petitioner(s) : Mr. Tapan Kumar Chandra, Advocate For Respondent No. 1 & 2/State : Mr. Shaleen Singh Baghel, Govt. Advocate Hon'ble Shri Ramesh Sinha, Chief Justice Hon'ble Shri Ravindra Kumar Agrawal, Judge Order on Board 14/05/2026 Per Ramesh Sinha, C. J. Since both the petitions arise out of the same FIR, involve identical and interconnected questions of fact and law and challenge the consequential criminal proceedings emanating therefrom, with consent of learned counsel appearing for the parties, both the matters were heard analogously and are being disposed of by this common order. 3 2. The petition (Cr.M.P.. 3567 of 2025) under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 has been preferred seeking quashment of FIR bearing Crime No.213/2025 registered at Police Station Dabhara, District Sakti (C.G.) for offences punishable under Sections 64(2)(f) and 85 of the Bharatiya Nyaya Sanhita, the consequential charge-sheet, cognizance order dated 29.08.2025 passed by the learned Judicial Magistrate First Class, Dabhara in Criminal Case No.1114/2025, order of committal and the charges framed vide order dated 16.10.2025 in Sessions Case No.41/2025 pending before the Court of learned Additional Sessions Judge (F.T.C.), Sakti, District Janjgir-Champa (C.G.). The petitioners, being aggrieved by the said order has sought for the following reliefs: 1. Allow the petition and kindly be pleased to quash the FIR No. 213/2025 registered under Section 64(2)(f) and 85 of the BNS at PS Dabhara, District Sakti (CG). 2. Quash the entire charge sheet relating to Crime No. 213/2025 registered under Section 64(2) (f) and 85 of BNS and also quash the cognizance order dated 29.08.2025 taken against the petitioners by the concerned trial court in relation to the Criminal Case No. 1114/2025. 3. Quash the order dated 16.10.2025 and plea of the charges dated 16.10.2025 passed in Sessions Case No. 41/2025 in which charges have been framed against the petitioner No.1 under Section 85, 115(2) of BNS and against the petitioner No.2 under 4 Section 85 ,64(20(f) and 351(3) of BNS and also quash the entire criminal proceedings relating to the Sessions Case No. 41/2025 pending before the Court of learned Additional Sessions Judge (FTC), Sakti, District Janjgir-Champa (CG). 4. Any other order, which this Hon’ble Court deems fit in the facts and circumstances of the case, in the interest of justice.” 3. The connected petition ie. (Cr.M.P. No. 1347 of 2026) under Section 483(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023 has been preferred calling in question the legality and propriety of the order dated 24.07.2025 passed in MCRCA No.1098/2025 whereby anticipatory bail has been granted in favour of one of the accused persons. By this petition, the petitioner has sought for the following relief: “This Hon’ble Court may kindly be pleased to allow the petition and cancel the anticipatory bail order dated 24.07.2025 (Annexure P/1) in the interest of justice.” 4. The facts, in brief, are that the marriage between Petitioner No.1 and Respondent No.2/complainant was solemnized on 06.04.2025 at Village Khairkala, P.S. & Tahsil Dabhara, District Sakti (C.G.) according to Hindu rites and customs. Prior to the aforesaid ceremonial marriage, the parties had also solemnized marriage voluntarily at Arya Samaj Mandir, Raipur on 12.02.2025. As per the prosecution case, after the 5 marriage, the complainant was subjected to physical and mental cruelty on account of unlawful demand of dowry amounting to Rs.15,00,000/- by the accused persons and she was harassed and ill- treated at her matrimonial home. 5. It has further been alleged by the complainant that on 15.04.2025, forcible sexual intercourse was committed upon her by one of the accused persons and thereby serious offences punishable under the provisions of the Bharatiya Nyaya Sanhita were committed. On the basis of the written complaint submitted by Respondent No.2/No.2/complainant, FIR bearing Crime No.213/2025 came to be registered at Police Station Dabhara, District Sakti for the offences punishable under Sections 64(2)(f) and 85 of the Bharatiya Nyaya Sanhita. 6. Upon completion of investigation, the Investigating Agency filed charge-sheet before the learned Judicial Magistrate First Class, Dabhara, which was registered as Criminal Case No.1114/2025 and cognizance was taken vide order dated 29.08.2025. Thereafter, the matter was committed to the Court of Sessions and charges were framed against the accused persons vide order dated 16.10.2025 in Sessions Case No.41/2025 pending before the Court of learned Additional Sessions Judge (F.T.C.), Sakti, District Janjgir-Champa (C.G.). 7. Learned counsel appearing for the petitioners submits that the impugned FIR and consequential criminal proceedings are manifestly accompanied with mala fide intention and have been initiated on the 6 basis of false, exaggerated and omnibus allegations arising out of matrimonial discord between the parties. It is contended that a bare perusal of the FIR and charge-sheet would demonstrate that no specific overt act has been attributed against the petitioners and the allegations made therein are vague, general and inherently improbable in nature. 8. Learned counsel further submit that prior to the ceremonial marriage performed at the native village, Petitioner No.1 and Respondent No.2/complainant had already solemnized marriage voluntarily at Arya Samaj Mandir, Raipur out of their own free will and consent and, therefore the subsequent allegations levelled by the complainant are liable to be viewed with great circumspection. It is further argued that due to matrimonial incompatibility and personal differences, disputes arose between the parties and the present criminal proceedings have been initiated only with an oblique motive to harass the petitioners and their family members. 9. It is submitted that after the marriage, due to matrimonial discord and personal incompatibility, the complainant voluntarily left the matrimonial house and repeatedly refused to reside with Petitioner No.1 despite several sincere efforts made by him to restore the matrimonial relationship. Learned counsel submits that Petitioner No.1 even took the complainant to his place of posting at Kanker (C.G.), however, she again returned to her parental house of her own accord. It is also contended that Petitioner No.2, being merely the elder brother of Petitioner No.1 and residing separately in connection with his 7 employment, has been falsely implicated without there being any material to prima facie establish his involvement in the alleged offences. 10. Learned counsel for the petitioners further submits that the FIR has been lodged only after the Petitioners came to know about the earlier relationship of the complainant with another person and, therefore, the present criminal proceedings have been initiated maliciously with an oblique motive to pressurize and harass the Petitioners. It is contended that except bald and omnibus allegations, no material particulars such as date, time or specific incident have been disclosed in the FIR or charge-sheet and, therefore, continuation of the impugned proceedings would amount to abuse of process of Court. 11. He further submits that during pendency of the present proceedings, the matter was referred to mediation for amicable settlement between the parties; however, the mediation proceedings failed and no settlement could be arrived at between them. Learned counsel for the Petitioners contends that the impugned FIR and the consequential criminal proceedings are manifestly an abuse of the process of law, having been instituted on the basis of false, exaggerated and concocted allegations solely with the intention to harass the Petitioners. It is submitted that a plain reading of the FIR and the charge-sheet would reveal that the allegations levelled therein are vague, omnibus and devoid of specific particulars regarding any alleged act of cruelty or demand of dowry attributable to the individual Petitioners. 8 12. It is also contended that continuation of the impugned criminal proceedings would amount to gross abuse of process of Court and the learned Courts below failed to appreciate the material available on record in its proper perspective while taking cognizance and framing charges. So far as the order granting anticipatory bail is concerned, learned counsel submits that the same is unsustainable in the eyes of law and liable to be set aside. 13. He submits that prior to registration of the impugned FIR, the complainant had approached the Mahila Thana, where efforts for counselling and reconciliation were undertaken, and at that stage she had not shown inclination for initiating criminal proceedings. However, subsequently, with mala fide intention and ulterior motive, the present FIR came to be lodged on false and fabricated allegations.It is thus contended that continuation of the criminal proceedings against the Petitioners would amount to gross misuse of the process of Court and, therefore, the same deserve to be quashed in exercise of inherent jurisdiction 14. Learned counsel for the Petitioners placed reliance upon the judgments of the Hon’ble Supreme Court in State of Haryana and others Vs. Bhajan Lal and others, 1992 Supp (1) SCC 335, Preeti Gupta and another Vs. State of Jharkhand and another, (2010) 7 SCC 667, Kahkashan Kausar @ Sonam and others Vs. State of Bihar and others, (2022) 6 SCC 599 and Abhishek Vs. State of Madhya Pradesh, 2023 SCC OnLine SC 1083 to contend that in cases involving vague and omnibus allegations, particularly against 9 relatives of the husband, continuation of criminal proceedings would amount to abuse of process of law and the same deserve to be quashed. 15. Per contra, learned State counsel as well as learned counsel appearing for Respondent No.2/complainant opposed the petitions and submit that the allegations levelled in the FIR, statements recorded during investigation and the material collected by the prosecution prima facie disclose commission of cognizable offences against the accused persons. It is submitted that after due investigation, sufficient incriminating material has been collected against the accused persons culminating into filing of the charge-sheet before the competent Court. 16. Learned State counsel submits that the impugned FIR and the consequential criminal proceedings have been initiated on the basis of a written complaint disclosing commission of cognizable offences and, upon due investigation, sufficient incriminating material has been collected against the accused persons, culminating into filing of the charge-sheet before the competent Court. It is submitted that the allegations levelled by Respondent No.2/complainant prima facie disclose commission of offences punishable under the relevant provisions of the Bharatiya Nyaya Sanhita and the learned trial Court, after due application of mind, has rightly taken cognizance and framed charges against the accused persons. 17. It is further submitted that the allegations levelled in the FIR cannot be said to beinherently improbable or absurd in nature so as to warrant interference by this Court in exercise of inherent jurisdiction 10 under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023. It is contended that the truthfulness, veracity and correctness of the allegations are matters of evidence which can only be adjudicated upon during the course of trial after full-fledged appreciation of oral and documentary evidence. 18. It is submitted that while exercising jurisdiction under Section 528 of the B.N.S.S., this Court may not embark upon a meticulous appreciation of evidence or adjudicate disputed questions of fact, which are required to be examined by the learned trial Court during trial. According to learned State counsel, the defence sought to be projected by the petitioners involves factual adjudication and the same cannot be conclusively determined in proceedings of the present nature. 19. The Investigating Agency, after conducting detailed investigation, has found sufficient material against the accused persons and, therefore, the criminal proceedings cannot be scuttled at the threshold. It is argued that the inherent powers of this Court are required to be exercised sparingly and with great caution and only in exceptional circumstances where no prima facie offence is made out. 20. The jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita is extraordinary and inherent in nature and the same is required to be exercised sparingly and with great caution. It is contended that disputed questions of fact requiring appreciation of evidence cannot be adjudicated upon in proceedings under Section 528 of the B.N.S.S. and the defence sought to be projected by the 11 petitioners can very well be examined by the learned trial Court during the course of trial. 21. Learned counsel appearing for Respondent No.2/complainant also opposed the petition and submits that the allegations levelled in the FIR specifically disclose that soon after the marriage, the complainant was subjected to physical and mental cruelty on account of unlawful demand of dowry and, therefore, a prima facie case is made out against the Petitioners. It is submitted that the allegations are not vague in nature and the same have been substantiated during investigation, pursuant to which charge-sheet has already been filed before the competent Court. 22. It is further submitted that the learned trial Court, upon due consideration of the material available on record, has rightly taken cognizance and framed charges against the Petitioners and the truthfulness or otherwise of the allegations can only be adjudicated upon during trial after appreciation of evidence. Hence, no interference is warranted by this Court in exercise of its inherent jurisdiction and the petition deserves to be dismissed. 23. We have heard learned counsel for the parties at considerable length and bestowed our anxious consideration to the rival submissions advanced at the Bar. We have also minutely perused the material available on record. 24. At the outset, it would be apposite to observe that the scope of interference by this Court while exercising jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita is extremely limited. It 12 is trite law that while exercising inherent jurisdiction for quashment of criminal proceedings, this Court is not expected to meticulously appreciate the evidence or adjudicate the correctness or otherwise of the allegations levelled in the FIR. The Court is only required to examine whether the allegations made in the FIR and the material collected during investigation prima facie disclose commission of cognizable offences and whether continuation of criminal proceedings would amount to abuse of process of Court. 25. The Apex Court in catena of decisions including State of Haryana and others Vs. Bhajan Lal and others, 1992 Supp (1) SCC 335, has consistently held that the extraordinary power of quashment is to be exercised sparingly, carefully and with abundant caution and only in exceptional cases where the allegations do not disclose commission of any offence or where the proceedings are manifestly attended with mala fide intention. 26. In the present case, upon perusal of the FIR, statements recorded under Section 180 of the B.N.S.S. and the material collected during investigation, this Court finds that the allegations levelled by Respondent No.2/complainant cannot be said to be wholly absurd, inherently improbable or entirely devoid of substance so as to warrant exercise of inherent jurisdiction at this stage. The allegations made in the FIR prima facie disclose commission of cognizable offences and the Investigating Agency, after due investigation, has already filed charge-sheet before the competent Court. 13 27. The present case admittedly arises out of a matrimonial dispute between Petitioner No.1 and Respondent No.2/complainant. From perusal of the FIR and the material collected during investigation, it appears that the allegations made against the Petitioners are primarily general and omnibus in nature. No specific overt act constituting the alleged offences has been attributed to Petitioner No.2, who is the elder brother of Petitioner No.1 and is stated to be residing separately in connection with his employment. 28. It is also not in dispute that prior to the ceremonial marriage performed on 06.04.2025, Petitioner No.1 and the complainant had already solemnized marriage at Arya Samaj Mandir, Raipur on 12.02.2025 out of their own volition and consent. The documents annexed with the petition prima facie indicate that the relationship between the parties was consensual prior to the matrimonial discord which subsequently arose between them. 29. In the matter of Pepsi Foods Ltd. and another v. Special Judicial Magistrate and others, the Apex Court has held that the accused can approach the High Court either under Section 528 of BNSS or under Article 227 of the Constitution of India to have the proceeding quashed against him when the complaint does not make out any case against him. 30. It would be apposite to consider the scope and ambit of interference by this Court while exercising inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 as well as jurisdiction under Section 483(3) of the B.N.S.S. The Apex Court in 14 State of Haryana and others Vs. Bhajan Lal and others, reported in 1992 Supp (1) SCC 335, while dealing with the parameters governing exercise of inherent powers for quashment of criminal proceedings, has categorically held that such powers are required to be exercised sparingly, carefully and with great caution and only in exceptional cases where the allegations made in the FIR, even if taken at their face value, do not prima facie constitute any offence or where continuation of criminal proceedings would amount to abuse of process of Court. Paragraph 102 of the aforesaid judgment reads thus: “102. In the backdrop of the interpretation of the various relevant provisions of the Code under Chapter XIV and of the principles of law enunciated by this Court in a series of decisions relating to the exercise of the extraordinary power under Article 226 or the inherent powers under Section 482 of the Code which we have extracted and reproduced above, we give the following categories of cases by way of illustration wherein such power could be exercised either to prevent abuse of the process of any court or otherwise to secure the ends of justice, though it may not be possible to lay down any precise, clearly defined and sufficiently The present case arises out of a matrimonial dispute between Petitioner No.1 (husband) and Respondent No.2/complainant (wife), whose marriage was solemnized on 12.06.2023 as per Hindu rites and customs, and out of the wedlock, one male child was born. As per the prosecution case, the respondent No.2 initially resided at her matrimonial home and the relations between the parties remained cordial for a brief period of about three months; however, thereafter, allegations have been made regarding change in 15 behaviour of the petitioners and demand of dowry in the form of an air-conditioner, coupled with mental and physical harassment. On the basis of such allegations, the respondent No.2 lodged a written report on 01.12.2024 at Police Station Sitapur, District Surguja, leading to registration of FIR bearing Crime No. 349/2024 for the offences punishable under Sections 115(2), 296 and 85 of the B.N.S. Upon completion of investigation, the police filed charge-sheet dated 05.07.2025 before the learned Judicial Magistrate First Class, Sitapur, which has been registered as Criminal Case No. 1458/2025, and cognizance has been taken by the learned trial Court vide order dated 05.07.2025, which is under challenge in the present petition.” 31. In State of Haryana and others Vs. Bhajan Lal and others, reported in 1992 Supp (1) SCC 335, the Hon’ble Supreme Court has authoritatively laid down the principles governing exercise of extraordinary jurisdiction for quashment of criminal proceedings. In paragraph 102 of the report, the Hon’ble Supreme Court illustratively enumerated the categories of cases wherein the inherent powers of the High Court may be exercised to prevent abuse of the process of law or otherwise to secure the ends of justice, including cases where the allegations made in the FIR, even if taken at their face value, do not disclose commission of any offence; where the allegations are so absurd and inherently improbable that no prudent person can ever reach a just conclusion against the accused; or where the criminal 16 proceeding is manifestly attended with mala fide andinstituted with an ulterior motive for wreaking vengeance upon the accused. 32. The Hon’ble Supreme Court, while sounding a note of caution in paragraph 103 of the said judgment, has further observed that the power of quashing criminal proceedings is required to be exercised sparingly, with circumspection, and only in the rarest of rare cases. It has been categorically held that while exercising such jurisdiction, the Court ought not to embark upon an enquiry regarding the reliability, genuineness or otherwise of the allegations levelled in the FIR or complaint, as the same fall within the domain of trial. 33. The aforesaid principles have consistently been reiterated and followed by the Apex Court in subsequent decisions including Google India Private Limited Vs. Visaka Industries, reported in (2020) 4 SCC 162, Ahmad Ali Quraishi and another Vs. State of Uttar Pradesh and another, reported in 2020 SCC OnLine SC 946, and Dr.Dhruvaram Murlidhar Sonar Vs. State of Maharashtra and others, reported in (2019) 18 SCC 191, wherein it has again been emphasized that the jurisdiction for quashment of criminal proceedings is extraordinary in nature and the same cannot be exercised to stifle a legitimate prosecution at its threshold when the allegations prima facie disclose commission of cognizable offences. 34. In the present case, upon a careful perusal of the FIR, charge- sheet and the material collected during investigation, this Court finds that the allegations levelled by Respondent No.2/complainant prima 17 facie disclose commission of cognizable offences and the same cannot be said to be so absurd, inherently improbable or patently mala fide so as to warrant interference by this Court in exercise of powers under Sections 528 and 483(3) of the B.N.S.S. The contentions raised on behalf of the petitioners involve disputed questions of fact requiring appreciation of evidence, which cannot be adjudicated in proceedingsof the present nature and are matters to be tested during the course of trial before the competent Court. 35. The Apex Court further observed that the extraordinary power of quashment should not be exercised to stifle a legitimate prosecution at its threshold. Similarly, in Neeharika Infrastructure Pvt. Ltd. Vs. State of Maharashtra and others, reported in (2021) 19 SCC 401, the Hon’ble Supreme Court exhaustively considered the principles governing quashment of FIR and criminal proceedings and held that the Court while exercising jurisdiction under Section 482 Cr.P.C. (now Section 528 B.N.S.S.) is not expected to conduct a mini trial or meticulously appreciate evidence.Paragraphs 12 and 23 of the aforesaid judgment read as under: “12. ... The power of quashing should be exercised sparingly with circumspection, in the rarest of rare cases. XXXX XXXXX XXXX “23. ... When a prayer for quashing the FIR is made by the alleged accused and the Court when exercises the power under Section 482 Cr.P.C., only has to consider whether the allegations in the FIR disclose commission of a cognizable offence or 18 not.” 36. Likewise, in R.P. Kapur Vs. State of Punjab, reported in AIR 1960 SC 866, the Apex Court has held that inherent powers can be exercised only where the allegations do not constitute any offence or where there exists a legal bar to institution or continuance of proceedings. 37. In the present case, upon careful perusal of the FIR, statements recorded during investigation and the material collected by the prosecution, this Court is unable to hold that the allegations levelled by Respondent No.2/complainant are so absurd or inherently improbable that no prudent person can ever reach a conclusion that anoffence has been committed. 38. The allegations levelled in the FIR prima facie disclose commission of cognizable offences against the accused persons and the Investigating Agency, after conducting investigation, has already filed charge-sheet before the competent Court. At this stage, this Court cannot undertake a meticulous examination of the truthfulness or otherwise of the allegations levelled by the complainant. 39. So far as the submissions advanced on behalf of the petitioners regarding false implication, prior consensual marriage, matrimonial discord and mala fide intention are concerned, the same involve seriously disputed questions of fact which require 19 appreciation of evidence and can only be adjudicated upon during the course of trial. 40. The Apex Court in State of Andhra Pradesh Vs. Golconda Linga Swamy and another, reported in (2004) 6 SCC 522, has held in paragraph 8 as under: “8. ... The Court at this stage would not embark upon an enquiry as to the reliability or genuineness or otherwise of the allegations made in the FIR or the complaint.” 41. Further, in Kaptan Singh Vs. State of Uttar Pradesh and others, reported in (2021) 9 SCC 35, the Apex Court reiterated that while exercising powers of quashment, the High Court cannot appreciate evidence or enter into disputed questions of fact. Paragraph 9 of the judgment reads as under: “9. ... Whether the allegations are true or untrue is to be decided on the basis of the evidence to be led during the trial and the High Court has erred in quashingthe criminal proceedings in exercise of powers under Section 482 Cr.P.C.” 42. So far as challenge to the order granting anticipatory bail is concerned, the Apex Court in Dolat Ram and others Vs. State of Haryana, reported in (1995) 1 SCC 349, has held that rejection of bail and cancellation of bail stand on different footings and bail once granted should not ordinarily be cancelled in a mechanical manner 20 unless supervening circumstances are brought on record. Paragraph 4 of the judgment reads thus: “4. ... Very cogent and overwhelming circumstances are necessary for an order directing the cancellation of the bail already granted.” 43. Reverting to the facts of the present case, this Court finds that the allegations levelled in the FIR and the statements recorded during the course of investigation prima facie disclose commission of cognizable offences against the petitioners. The complainant has specifically alleged that soon after the marriage, she was subjected to physical and mental cruelty on account of unlawful demand of dowry and was harassed by the accused persons. The allegations made in the FIR cannot be said to be so absurd, inherently improbable or wholly unbelievable so as to warrant interference by this Court in exercise of inherent jurisdiction under Section 528 and supervisory jurisdiction under Section 483(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023. 44. Upon perusal of the charge-sheet and the material collected during investigation, this Court is of the considered opinion that thecontentions advanced on behalf of the petitioners involve disputed questions of fact requiring appreciation of evidence, which cannot be adjudicated in proceedings of the present nature. The defence sought to be projected by the petitioners, including the plea regarding earlier relationship of the complainant, alleged false implication and absence of specific overt acts, are matters which can appropriately be examined 21 by the learned trial Court during the course of trial after affording opportunity to the parties to lead evidence 45. This Court is further of the view that at the stage of consideration of a petition for quashment, a meticulous appreciation of evidence is impermissible and the Court is only required to examine whether the allegations made in the FIR and the material collected during investigation disclose a prima facie case. 46. In the present case, the material available on record does disclose prima facie commission of offences and, therefore, this Court does not find any exceptional circumstance warranting exercise of extraordinary jurisdiction for quashing of the impugned FIR, charge- sheet, cognizance order and consequential criminal proceedings. 47. The principles laid down by the Apex Court in State of Haryana and others Vs. Bhajan Lal and others, reported in 1992 Supp (1) SCC 335, Google India Private Limited Vs. Visaka Industries, reported in (2020) 4 SCC 162, Dr. Dhruvaram MurlidharSonar Vs. State of Maharashtra and others, reported in (2019) 18 SCC 191 and other subsequent decisions clearly lay down that the inherent powers of the High Court are to be exercised sparingly, with circumspection and only in the rarest of rare cases. The present case does not fall within any of the categories illustratively enumerated in paragraph 102 of Bhajan Lal (supra) so as to justify quashment of the criminal proceedings at the threshold. 48. Consequently, in view of the aforesaid legal position and having regard to the facts and circumstances of the case, this Court is of the 22 considered opinion that no case for interference is made out. Accordingly, the impugned FIR, charge-sheet, cognizance order and the order framing charges do not warrant any interference by this Court. 49. Resultantly, both the petitions i.e. CRMP No. 3567 of 2025 preferred under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 and CRMP No. 1347 of 2026 preferred under Section 483(3) of the Bharatiya Nagarik Suraksha Sanhita, 2023 are hereby dismissed and disposed of analogously. 50. The learned trial Court is directed to proceed with the trial strictly in accordance with law and make all endeavour to conclude the same expeditiously, preferably within a period of six months from the date of receipt of certified copy of this order, if there is no legal impediment or other unavoidable circumstance. No order as to costs. Sd/- Sd/- (Ravindra Kumar Agrawal) (Ramesh Sinha) Judge Chief Justice SUGUNA DUBEY Digitally signed by SUGUNA DUBEY Date: 2026.05.18 11:08:04 +0530