Criminal proceedings cannot be quashed where charge-sheet materials disclose a prima facie offence requiring trial.

Respondent No. 2 alleged that, following her marriage to the petitioner on 5 March 2021, he and his family demanded dowry, including ₹10 lakh, gold and silver ornaments, and that the petitioner later subjected her to physical and mental harassment, demanded additional dowry, and threatened her.

Police registered a case and, after investigation, filed a charge-sheet against the petitioner under Sections 498A and 504 of the IPC and Sections 3 and 4 of the Dowry Prohibition Act; the Magistrate took cognizance.

The petitioner sought quashing of the proceedings under Section 482 CrPC, stated in the petition to be filed under Section 528 BNSS, arguing that the allegations were omnibus and did not disclose offences.

1. Whether the complaint and charge-sheet materials, taken at face value, disclosed a prima facie case against the petitioner under Sections 498A and 504 IPC and Sections 3 and 4 of the Dowry Prohibition Act.

2. Whether the proceedings should be quashed under the High Court’s inherent jurisdiction at that stage.

The petition invoked the High Court’s inherent jurisdiction under Section 482 CrPC (and referred to Section 528 BNSS) to seek quashing.

The Court applied the principle that proceedings may be quashed where the complaint discloses no offence or is frivolous, vexatious, or oppressive; where the allegations disclose the ingredients of the offences, the Court should not conduct a meticulous pre-trial assessment of whether conviction is likely.

It relied on *Sau. Kamal Shivaji Pokarnekar v. State of Maharashtra*, (2019) 14 SCC 350.

The complaint alleged specific dowry demands and harassment, including the payment of cash and transfer of gold and silver ornaments, and the investigation materials included supporting statements from material witnesses.

The Court held that these materials disclosed a prima facie case and that their veracity should be tested at trial.

It declined to undertake a detailed appreciation of evidence or determine whether the petitioner would ultimately be convicted.

The criminal petition was dismissed, without expressing any opinion on the merits of the case.