Disputed Factual Allegations and Allegations of Mala Fides Cannot Justify Quashing FIR Under Section 482 CrPC

The petitioner, a contractor for Northern Coalfields Limited (NCL), sought quashment of FIR No. 70/2018 registered under Sections 294, 323, 353, 506, 332, and 333 of the IPC.

The petitioner alleged that Respondent No. 2, a Senior Manager at NCL, demanded illegal gratification to clear pending bills worth Rs. 60 lakhs and, following the petitioner’s complaints to higher authorities, developed animosity.

The petitioner contended that on March 15, 2018, Respondent No. 2 assaulted him but fell and sustained accidental/self-inflicted injuries during the altercation.

Conversely, the FIR alleged that the petitioner assaulted a public servant while discharging official duties.

1. Whether the inherent powers of the High Court under Section 482 of the CrPC should be exercised to quash an FIR when the allegations prima facie disclose the commission of cognizable offences.

2. Whether the existence of prior disputes, claims of mala fide intention, or counter-allegations of accidental injury are sufficient grounds to quash a criminal proceeding at the investigation stage.

The court applied Section 482 of the Code of Criminal Procedure, 1973, which empowers the High Court to prevent abuse of the process of law or to secure the ends of justice, noting that such power must be used sparingly.

The court adhered to the principle that an FIR can only be quashed if the allegations, taken at face value, do not disclose the commission of any offence.

The Court further applied the penal provisions for assaulting a public servant under Sections 353, 332, and 333 of the Indian Penal Code.

The Court observed that the FIR contained specific allegations of an assault on a public servant during the discharge of official duties, which was corroborated by medical evidence of injuries sustained by Respondent No. 2.

The Court reasoned that the petitioner’s defense—characterizing the FIR as a "counterblast" to his corruption complaints and claiming the injuries were accidental—raised disputed questions of fact.

Under Section 482 CrPC, the High Court cannot adjudicate such factual disputes or weigh the evidence, as these are matters for investigation and trial.

The Court emphasized that prior enmity or pending civil/financial disputes do not negate the legal validity of a cognizable criminal complaint if the ingredients of the offence are prima facie present in the FIR.

The Court dismissed the petition.