FIR quashed where allegations failed to disclose the essential ingredients of the charged offences.

The second respondent, a manager at Santhi Feeds (P) Ltd., complained that on 11 January 2026 the petitioner and others obstructed vehicles transporting chicks, intercepted one vehicle, pelted it with stones, damaged it and threatened its driver and cleaner.

The police registered Crime No. 10 of 2026 under Sections 191(2), 126(2), 296(b) and 351(3) of the Bharatiya Nyaya Sanhita, 2023 (BNS), and Section 5 of the Tamil Nadu Public Property (Prevention of Damage and Loss) Act, 1992.

The petitioner contended that the conduct arose from a farmers’ campaign over poultry wages and a non-violent production stoppage, preceded by notices to public authorities.

He sought quashing of the FIR under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

1. Whether the allegations disclosed the ingredients of rioting, wrongful restraint, obscene words in or near a public place, or criminal intimidation under the cited BNS provisions.

2. Whether the FIR was liable to be quashed as an abuse of process under the High Court’s inherent jurisdiction.

Section 191(2) BNS requires rioting by an unlawful assembly acting in furtherance of a common object and the use of force or violence.

Section 126(2) BNS concerns wrongful restraint of a person from proceeding in a direction in which that person has a right to proceed.

For Section 296(b) BNS, the judgment required the utterance of obscene words in or near a public place and annoyance to others; it relied on K. Jeyaramanuju v. Janakaraj & Anr., 1996 (1) CTC 470, for the proposition that utterance alone is insufficient without proof of annoyance.

For Section 351(3) BNS, the Court identified a threat and an intention to cause alarm or to compel a person to act or refrain from acting as necessary ingredients.

The Court also relied on the category in Bhajan Lal v. State of Haryana permitting quashing where proceedings are manifestly malicious or instituted with an ulterior motive.

The Court found the allegations of unlawful assembly, common object and violence insufficiently specific to make out rioting, and held that no particular act of wrongful restraint was attributed to the petitioner.

It further found no specified obscene words or allegation establishing that anyone was annoyed, and considered the alleged threats ineffective and lacking the requisite intention to cause alarm.

On that basis, it characterized the FIR as an abuse of process and liable to be quashed.

Although the FIR also invoked Section 5 of the Tamil Nadu Public Property Act, the judgment did not separately analyze that provision.