A satisfactorily explained delay in lodging an FIR does not warrant quashing proceedings.

The petitioners, accused Nos. 1–3, sought to quash proceedings in C.C. No. 12/2023, arising from Crime No. 95/2022 of Badami Police Station, for offences under Sections 323, 354(B), 448, 504 and 506 read with Section 34 of the IPC

The complaint alleged that on 23 May 2022 the petitioners entered the school where the complainant worked, demanded keys and school-management documents, assaulted and abused her, pulled her veil, and threatened to eliminate her

The complaint was lodged on 16 June 2022, 24 days after the alleged incident; after investigation, police filed a charge sheet

The petitioners contended that the case was falsely instituted amid a school-management dispute and that the charge-sheet material did not disclose the offences

1. Whether the 24-day delay in lodging the complaint justified quashing the criminal proceedings

2. Whether the charge-sheet material disclosed a prima facie case warranting continuation of the proceedings, or whether the High Court should quash them under Section 482 CrPC / Section 528 BNSS

The petition invoked the High Court’s inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973, corresponding to Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, to seek quashing of the proceedings

In State of Andhra Pradesh v. Madhusudhan Rao, (2008) 15 SCC 582, the Supreme Court observed that unexplained delay in lodging an FIR may raise concerns about embellishment or deliberation, and that the delay should be satisfactorily explained

However, Punit Beriwala v. State of NCT of Delhi, 2025 SCC OnLine SC 983, and Skoda Auto Volkswagen (India) Private Limited v. State of Uttar Pradesh, (2021) 5 SCC 795, establish that delay alone is not a ground to quash an FIR; where the explanation’s plausibility is in dispute, it is ordinarily for the trial court to assess after evidence

The Court noted the 24-day delay but held it was not, by itself, a basis to quash the proceedings, particularly as the complainant had explained it

It also found that the complainant and two alleged eyewitnesses, CWs 4 and 5, had made statements supporting the allegations, including that the petitioners abused the complainant and outraged her modesty by pulling her veil

Since the petitioners’ objections concerned disputed facts and the materials disclosed a prima facie case, those matters were not appropriate for determination in proceedings under Section 482 CrPC

Any pending interlocutory applications were disposed of as not surviving for consideration, and the trial court was directed to proceed in accordance with law, without being influenced by the High Court’s observations