Criminal proceedings quashed where allegations of forgery are inherently improbable and motivated by institutional resentment.

The petitioner, a renowned oncologist, served Manipal Hospital (Respondent No. 2) for 19 years in senior capacities.

In 2022, he resigned to join Aster DM Healthcare as Director of Oncology Services.

Subsequently, a verification agency (Dataflow Services) contacted Manipal Hospital regarding an experience certificate and logbook submitted by the petitioner.

Respondent No. 2 filed a criminal complaint alleging the petitioner forged a signature on the certificate, leading to FIR No. 277/2022 under Sections 465 and 471 IPC.

The police filed a ‘B’ report (closure report) finding no material to prosecute.

However, the Magistrate rejected the ‘B’ report and took cognizance based on a protest petition supported by a private forensic lab report.

The petitioner moved the High Court to quash the proceedings.

1. Whether the Magistrate was justified in taking cognizance of the offences under Sections 465 and 471 IPC based on a private forensic report and a rejected ‘B’ report.

2. Whether the criminal proceedings initiated against the petitioner constitute an abuse of the process of law intended for institutional retaliation.

The court primarily applied Section 482 of the Cr.PC (analogous to Section 528 BNSS) regarding the inherent power of the High Court to prevent abuse of legal process.

It strictly applied the guidelines from State of Haryana v. Bhajan Lal, which mandate quashing if allegations are "absurd," "inherently improbable," or "maliciously instituted with an ulterior motive for wreaking vengeance".

The court also applied the evidentiary principle that forensic examination must be conducted by an authorized Government Forensic Science Laboratory (FSL) rather than a private entity to sustain a criminal prosecution.

The Court observed that the petitioner was a doctor of "unquestionable" repute whose 19-year tenure at Manipal Hospital was a matter of fact; thus, he had no material motive to forge a certificate for experience he genuinely possessed.

The court noted that the prosecution was "founded upon absurdity" and appeared to be a "heart-burn" reaction to the petitioner and his staff joining a competing hospital.

Critically, the Court found that the Magistrate erred by relying on a private forensic report, which lacks the legal credence of a state-authorized FSL report.

The Court reasoned that the proceedings were "manifestly attended with mala fide" and intended to "arm-twist" a professional, falling squarely within the categories for quashing established in Bhajan Lal.

It emphasized that doctors should not be drawn into the "dragnet of criminal law" over inter-hospital institutional resentment.

The Court allowed the petition and quashed the entire proceedings in C.C.No.70189 of 2024 arising out of Crime No. 277/2022.

The High Court characterized the case as a "patent abuse of the process of law" where criminal machinery was used as a weapon for "institutional displeasure".