Disputed factual questions cannot be adjudicated in quashing proceedings once criminal charges are framed.

The petitioner sought to quash the charges and criminal proceedings arising out of Crime No. 66/2022 registered at Police Station Navagarh for offences under Sections 409, 420, 384, 345, and 120-B of the IPC.

The prosecution alleged that in July 2017, the petitioner impersonated an Axis Bank employee to forcibly take away a tractor and trolley belonging to the complainant's father under the pretext of non-payment of loan installments.

The petitioner argued that the FIR was delayed by five years, the dispute was purely civil, and he was an employee of a different agency with no nexus to the bank.

Following the investigation, a charge-sheet was filed, and the Judicial Magistrate First Class, Bemetara, framed charges against the petitioner.

Whether the criminal proceedings and the framing of charges against the petitioner warrant quashing under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023.

The Court applied Section 528 of the BNSS, 2023 (corresponding to Section 482 of the CrPC), which preserves the inherent powers of the High Court to prevent abuse of the process of law.

It relied on the settled legal principle that the power to quash proceedings must be exercised sparingly and with circumspection, only in cases where allegations are patently absurd or fail to disclose a cognizable offence.

Furthermore, the court noted that at the stage of framing charges, the trial court is required only to determine the existence of a prima facie case and is prohibited from conducting a mini-trial or detailed appreciation of evidence.

The High Court observed that the Trial Court had already applied its mind and framed charges based on the material collected during the investigation, which prima facie indicated the commission of cognizable offences.

The Court found that the grounds raised by the petitioner—including the five-year delay in lodging the FIR, the petitioner's actual place of employment, and the circumstances of the vehicle's seizure—constituted "disputed questions of fact".

The Court reasoned that such factual disputes cannot be adjudicated in a summary proceeding for quashing but must be tested through a full trial where evidence can be properly appreciated.

Consequently, the allegations were not found to be so inherently improbable as to justify the extraordinary interference of the High Court.

The Court affirmed that because a prima facie case was established and charges had already been framed, the petitioner must undergo trial to resolve the disputed factual contentions.

All reliefs sought by the petitioner were denied.