FIR and charge-sheet cannot be quashed when material on record prima facie discloses cognizable offences.

The petitioners filed a petition under the inherent jurisdiction of the High Court seeking to quash FIR No. 281/2025 and the subsequent charge-sheet dated 20.02.2026

The FIR was registered based on a complaint by Respondent No. 3, alleging that the petitioners assaulted his family with weapons during a land dispute

The petitioners contended that the dispute was purely civil, governed by a status quo order from the Commissioner, Surguja Division

They further alleged that the police acted mala fide, introduced stringent provisions of the SC/ST Act without foundational allegations, and ignored a counter-FIR filed by the petitioners

By the time of the hearing, the investigation was complete, a charge-sheet had been filed, and the Special Judge (SC/ST Act), Jashpur, had taken cognizance

1. Whether the FIR and consequential criminal proceedings should be quashed on the grounds of being a civil dispute turned criminal or on the basis of alleged mala fides

2. Whether the High Court should interfere with the proceedings after a charge-sheet has been filed and cognizance has been taken by the trial court

The Court applied the principles governing the inherent powers of the High Court to quash criminal proceedings, primarily focusing on whether the FIR/charge-sheet prima facie discloses the commission of cognizable offences

The court recognized the interplay between the Bharatiya Nyaya Sanhita, 2023 (specifically Sections 296, 351(2), 115(2), 109, and 191(3)) and the Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989

The court relied on the doctrine that disputed questions of fact, including pleas of alibi and mala fides, cannot be adjudicated under quashing jurisdictions but must be tested during trial through the appreciation of evidence

The Court observed that while the dispute had a civil undertone involving land possession, the allegations in the FIR and the material collected during the investigation—including witness statements, medical evidence, and weapon recoveries—prima facie indicated the commission of criminal acts

The court noted that because a counter-FIR existed, the incident involved rival versions of the same transaction, which necessitates a trial to determine the truth

The petitioners' arguments regarding false implication, physical impossibility (alibi), and contradictions in the medical evidence were deemed "disputed questions of fact"

Since the competent court had already perused the charge-sheet and taken cognizance, the High Court determined that any intervention at this stage would amount to a premature appreciation of evidence

The Court held that since the material on record prima facie discloses the commission of offences and the trial court has already taken cognizance, there is no ground for quashing the FIR or the consequential proceedings

The petitioners were liberty to establish their defense, including the plea of mala fides and the counter-case, before the trial court. Case dismissed