Disputed factual questions and alibi claims are matters of defense, not grounds for quashing FIR.

The petitioner, a journalist, sought the quashing of FIR Crime No. 82/2026 registered at Police Station Nawagarh under Sections 296, 351(3), 191(2), 191(3), and 109 of the Bharatiya Nyaya Sanhita (BNS), 2023

The complainant (Respondent No. 2) alleged that on March 2, 2026, the petitioner and several others assaulted his son with iron rods and sticks, and subsequently assaulted the complainant with deadly weapons when he attempted to intervene, causing head injuries

The petitioner contended that he was falsely implicated as an act of revenge following a prior FIR (Crime No. 81/2026) filed against the complainant’s son.

He maintained that his presence was limited to a hospital for professional news coverage and that he was not present at the scene of the crime

1. Whether the High Court should exercise its inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 to quash an FIR when the accused claims false implication and an alibi

2. Whether the allegations in the FIR, taken at face value, disclose the commission of cognizable offences

The court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (formerly Section 482 of the CrPC), which preserves the High Court's inherent power to prevent abuse of the process of law

It relied on the settled legal principles established in State of Haryana v. Bhajan Lal, Neharika Infrastructure Pvt. Ltd. v. State of Maharashtra, and State of Orissa v. Saroj Kumar Sahoo, which dictate that the power to quash criminal proceedings is extraordinary and must be exercised sparingly

The core doctrine is that at the quashing stage, the Court must not conduct an inquiry into the reliability of allegations, adjudicate disputed questions of fact, or appreciate evidence that belongs to the trial stage

The Court observed that the petitioner was specifically named in the FIR with clear attributions of participation in a violent assault

It determined that the petitioner’s claims—namely his status as a journalist and his plea of alibi—constituted "disputed questions of fact" and matters of defense that require a full trial for determination

The bench noted that the investigation was at a crucial stage and that witness statements collected by the prosecution prima facie supported the allegations

Applying the Bhajan Lal standards, the Court found that the allegations were neither "absurd" nor "inherently improbable"

Consequently, the Court held that it could not interfere under Section 528 BNSS as the FIR disclosed the commission of cognizable offences on its face

The Court concluded that the petitioner's defense of false implication must be tested during the investigation and trial rather than at the threshold stage of quashing

The prayer to quash Crime No. 82/2026 was denied