A High Court cannot quash proceedings under Section 482 CrPC by assessing disputed defence evidence.

The petitioner sought quashing under Section 482 Cr.P.C. of the charge-sheet and consequential proceedings in Crime No. 10/2022, registered at Ganj Police Station, Betul, for offences under Sections 341, 354 and 354-D IPC.

The FIR alleged an incident on 11 January 2022 and was lodged the following day.

The petitioner argued that it was a counterblast to an earlier FIR he had lodged against respondent No. 2 and her father, and relied on, among other things, a pending divorce petition, photographs, WhatsApp messages and material concerning unavailable CCTV footage.

The State opposed quashing, submitting that the FIR and statements identified the petitioner and that the investigation had collected sufficient material to file the charge-sheet.

Respondent No. 2 made no submissions.

Whether the allegations and material in the charge-sheet warranted quashing of the criminal proceedings under Section 482 Cr.P.C.

Whether the petitioner’s defence materials and disputed claim that respondent No. 2 was his wife could be determined in a quashing petition.

Section 482 Cr.P.C. empowers the High Court to quash proceedings to prevent abuse of process or secure the ends of justice, but the power must be exercised sparingly and with circumspection.

Applying the principles in Amit Kapoor v. Ramesh Chander, as reiterated in Supriya Jain v. State of Haryana, and the categories in State of Haryana v. Bhajan Lal, the Court must consider whether the allegations, taken at face value, disclose an offence; it must not conduct a mini-trial or assess the truth, reliability or sufficiency of the evidence.

CBI v. Aryan Singh, Abhishek v. State of M.P., State of Maharashtra v. Maroti and other cited authorities further establish that disputed facts and defence materials generally cannot be evaluated to determine guilt or likely acquittal at this stage.

The Court treated the petitioner’s claim that respondent No. 2 was his wife, along with the photographs, divorce proceedings and related criminal appeal, as matters involving disputed facts that could not be resolved under Section 482 Cr.P.C.

The petitioner’s challenges to the allegations and the investigation likewise raised matters of evidence for trial, not grounds for quashing at the threshold.

The Court therefore declined to assess the defence or conduct a detailed examination of the evidence.

It directed that the trial court proceed in accordance with law, uninfluenced by the High Court’s observations, which were confined to deciding the petition.