Factual disputes and specific allegations in FIR preclude quashing of criminal proceedings under BNS.

The petitioner sought to quash FIR No. 296/2025 and the subsequent charge-sheet filed under Sections 109 and 3(5) of the Bharatiya Nyaya Sanhita (BNS).

The prosecution alleged that on May 16, 2025, the petitioner and a juvenile co-accused, motivated by old enmity, assaulted the complainant’s brother, Pramod Yadav.

The juvenile allegedly stabbed the victim repeatedly with a button knife while the petitioner participated in the assault.

The petitioner argued he was falsely implicated due to previous enmity, played no role in the incident, and that no incriminating articles were recovered from him.

Whether the FIR and criminal proceedings against the petitioner should be quashed on the ground that no prima facie case is made out under the BNS.

Whether the High Court can adjudicate disputed questions of fact regarding the petitioner’s presence and involvement at the scene of the crime during a quashing petition.

The Court applied Section 482 of the Code of Criminal Procedure (corresponding to the relevant saving provisions for High Court inherent powers) regarding the quashing of FIRs and criminal proceedings.

It relied on the established legal principle that proceedings should not be quashed if the allegations in the FIR, taken at face value, disclose the commission of a cognizable offence.

Furthermore, the court applied the principle that meticulous examination of evidence or adjudication of disputed facts is impermissible at the preliminary stage of a quashing petition.

The Court observed that the petitioner was specifically named in the FIR and that a clear role in the assault was attributed to him.

It rejected the petitioner's defense of "false implication" and "absence from the spot," noting that these are disputed questions of fact that require a full trial and the appreciation of evidence.

The Court found that the allegations were not "inherently improbable or absurd" and that the charge-sheet, supported by witness statements recorded during the investigation, provided sufficient material to proceed.

The Court reasoned that since the petitioner allegedly shared a common intention with the co-accused to facilitate the assault, the ingredients of the BNS were prima facie satisfied.

The petition was dismissed, and the prayer to quash the FIR (No. 296/2025) and the criminal proceedings (Case No. 5633/2025) was denied.