Criminal proceedings cannot proceed where FIR allegations fail to disclose the essential ingredients of the charged offences.

The second respondent, a manager at Suguna Foods (P) Ltd., complained that on 10 and 11 January 2026 the petitioners obstructed vehicles transporting chicks to farms. The complaint alleged that, on 11 January, the petitioners intercepted a vehicle, pelted stones at it, damaged it, and threatened its driver and cleaner.

The petitioners maintained that their actions formed part of a non-violent farmers’ campaign for increased poultry-rearing wages, preceded by notices to the authorities.

The police registered Crime No. 24 of 2026 under Sections 191(2), 126(2), 296(b) and 351(2) of the Bharatiya Nyaya Sanhita, 2023 (BNS), and Section 5 of the Prevention of Damage to Public Property Act, 1984. The petitioners sought to quash the FIR under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Whether the allegations in the FIR disclosed the ingredients of rioting under Section 191(2) BNS and wrongful restraint under Section 126(2) BNS.

Whether the allegations disclosed the ingredients of an offence under Section 296(b) BNS or criminal intimidation under Section 351(2) BNS.

Whether the FIR warranted quashing under the High Court’s inherent jurisdiction.

The Court applied Section 528 of the BNSS, under which the petitioners invoked the High Court’s inherent power to seek quashing of the FIR.

It considered Section 191(2) BNS, requiring an unlawful assembly and use of force or violence in furtherance of its common object, and Section 126(2) BNS, requiring wrongful restraint of a person from proceeding in a direction in which that person has a right to proceed.

For Section 296(b) BNS, the Court relied on the requirement that obscene words be uttered in or near a public place to the annoyance of others; it cited K. Jeyaramanuju v. Janakaraj & Anr., 1996 (1) CTC 470, for the proposition that utterance alone is insufficient without proof of annoyance.

For Section 351(2) BNS, the Court identified a threat and an intention to cause alarm as essential ingredients.

It also referred to the categories for quashing criminal proceedings in State of Haryana v. Bhajan Lal, cited in the order as (1992) SCC Crl. 426, including proceedings manifestly attended by mala fides and instituted to wreak vengeance.

The Court concluded that the FIR did not make out the invoked offences against the petitioners. It treated the allegations of rioting as vague and omnibus, without a sufficiently identified unlawful assembly, common object, or specific violent act attributable to the petitioners; it also found no specific allegation that any petitioner personally restrained another person.

As to Section 296(b), the FIR did not identify obscene words or show that anyone was annoyed by them.

As to Section 351(2), the Court considered the alleged threats to be empty and without effect on the complainant.

It consequently characterized the FIR as an abuse of process and liable to be quashed.

The connected miscellaneous petition was closed.