Digital toll records supporting an alibi cannot justify quashing proceedings before trial.

Opposite Party No. 2 alleged that the petitioners assaulted him near Maligram Bazar on 8 December 2022. The police registered a case under Sections 341, 323, 325, 307, 379, 506 and 34 IPC; after investigation, the charge sheet proceeded under Sections 341, 323, 307, 506 and 34 IPC. The Magistrate took cognizance and issued arrest warrants.

The petitioners sought to quash the proceeding under Section 482 CrPC, relying on FasTag records said to place their vehicle more than 85 kilometres from the alleged scene at the relevant time, the absence of external injury in the medical report, and pending civil litigation between the parties.

The State and complainant opposed quashing, arguing that these matters raised factual questions for trial.

1. Whether the petitioners’ plea of alibi, supported by digital toll-plaza records, could be evaluated at the quashing stage or was a disputed question of fact for trial.

2. Whether the pending civil litigation and the alleged lack of medical corroboration rendered the prosecution an abuse of process warranting quashing.

Section 482 CrPC confers an extraordinary inherent power to be exercised sparingly; a court should not quash proceedings where the allegations and investigation materials disclose a prima facie case or conduct a mini-trial on disputed facts [State of Haryana v. Bhajan Lal, 1992 Supp (1) SCC 335, paras. 12, 14(i)].

A plea of alibi is a question of fact requiring proof at trial, and the reliability of defence documents cannot ordinarily be determined in a summary quashing proceeding [State of Karnataka v. Pastor P. Raju, (2006) 6 SCC 728; Rajesh Talwar v. CBI, (2012) 4 SCC 217; Sanjay Kumar Rai v. State of Uttar Pradesh, (2021) 15 SCC 720, para. 11].

Civil and criminal proceedings may coexist; a civil dispute does not, by itself, bar prosecution [Mitesh Kumar J. Sha v. State of Karnataka, (2022) 14 SCC 572, para. 12].

The court may not assess the sufficiency or merits of investigation evidence at the quashing stage [Rajeev Kourav v. Baisahab, (2020) 3 SCC 317, para. 13].

The charge sheet, witness statements and medical material were considered sufficient to cross the prima facie threshold. The FasTag records and travel-time calculations could not establish the petitioners’ presence or absence without proof and testing at trial; the Court therefore treated the alibi as a disputed factual defence.

The pending title suit did not automatically establish that the complaint was fabricated, and the medical report’s weight, including its bearing on the Section 307 IPC allegation, was left for consideration at charge framing or trial. The Court declined to evaluate those matters in a Section 482 proceeding.

It dismissed the criminal revision and disposed of the connected application, made no order as to costs, and directed the trial court to proceed expeditiously in accordance with law, uninfluenced by its observations.