Criminal proceedings cannot be quashed where charge-sheet material prima facie discloses the accused’s involvement.

Respondent No. 2 alleged that, following an altercation on 12 September 2023, the petitioners abused and assaulted her and her husband, causing injuries and threatening them.

The dispute arose against the background of an earlier property-related disagreement and a prior police complaint that had been registered as a non-cognizable report.

Police registered a case for offences under Sections 506, 504, 323 and 354 read with Section 149 IPC. An initial charge sheet was filed against three petitioners; after further investigation, an additional charge sheet was filed against the remaining petitioners.

The petitioners sought to quash the proceedings, alleging that the case was retaliatory, the eyewitness statements were delayed, the complainant had improved her account, and the allegations and evidence were insufficient.

1. Whether the criminal proceedings and charge sheets should be quashed under Section 482 CrPC where the petitioners alleged that the complaint was motivated by a civil dispute and that the evidence was unreliable or insufficient.

2. Whether the charge-sheet material, including eyewitness statements, wound certificates and CCTV footage, disclosed a prima facie case requiring the matter to proceed to trial.

The Court considered its inherent jurisdiction under Section 482 CrPC (the petition also referred to Section 528 BNSS) to quash criminal proceedings.

It stated that quashing is warranted where the complaint discloses no offence or is frivolous, vexatious or oppressive; however, the Court should not conduct a meticulous assessment of the evidence or determine, before trial, whether the case will end in conviction or acquittal. Where the allegations and supporting material disclose the ingredients of an offence, interference is not justified (Sau. Kamal Shivaji Pokarnekar v. State of Maharashtra, (2019) 14 SCC 350).

The alleged offences were under Sections 506, 504, 354 and 323 IPC, with Section 149 IPC invoked in the FIR and additional charge sheet.

The Court found that the complaint described an assault and that the complainant and her husband had received outpatient treatment soon after the incident; the recorded medical history referred to the alleged assault.

Eyewitness statements and CCTV footage were said to show the petitioners’ presence and alleged participation.

The Court treated the alleged delay in recording witness statements and the complainant’s subsequent improvement as matters for evaluation at trial, not grounds for quashing at this stage.

Because the materials prima facie supported the allegations, the Court declined to weigh their ultimate reliability or sufficiency.

It dismissed the petition and refused to quash the proceedings in C.C. No. 21/2024, without expressing an opinion on the merits.