High Courts should not quash criminal proceedings where prima facie material supports prosecution.

The petitioner sought to quash the charge-sheet and criminal proceedings for offences under Sections 420, 467, 468 and 471 of the IPC, and to set aside the orders refusing his discharge application under Section 239 CrPC.

The prosecution alleged that he represented himself as an RTI activist associated with the Prime Minister’s Office and used that claim to obtain confidential information and harass the complainant

The Magistrate rejected the discharge application, and the revisional court affirmed that decision, relying in part on a PMO communication stating that no such department existed and that the petitioner was not associated with the PMO.

The petitioner then invoked the High Court’s jurisdiction under Section 528 BNSS

Whether the charge-sheet and criminal proceedings should be quashed on the ground that the alleged facts did not disclose offences under Sections 420, 467, 468 and 471 IPC, or that only an offence under Section 419 IPC was made out

Whether the orders refusing discharge and dismissing the revision disclosed perversity, illegality, or another basis for interference under the High Court’s inherent jurisdiction

Whether the petitioner was entitled to a certificate for appeal under Article 134(1)(c), read with Article 134-A, of the Constitution

Section 239 CrPC provides for discharge where the charge is groundless; Sections 420, 467, 468 and 471 IPC prescribe the offences alleged in this case.

In exercising inherent jurisdiction under Section 528 BNSS (corresponding to Section 482 CrPC), the High Court may interfere where the challenged order lacks a legal foundation, is perverse, or risks a failure of justice; it should not otherwise stifle criminal proceedings where the record discloses prima facie material.

The Court relied on Accamma Sam Jacob v. State of Karnataka, 2026 INSC 362, including its caution against prematurely evaluating disputed matters or conducting a mini-trial

Article 134(1)(c), read with Article 134-A, permits a certificate for appeal where the requisite basis for such certification exists

The Court considered the PMO communication confirming that the petitioner was not associated with the Office and that the department he claimed to represent did not exist. It held that this, together with the material considered by the courts below, constituted prima facie material supporting continuation of the proceedings.

The Magistrate’s and revisional court’s orders therefore could not be said to be perverse or illegal, and the petitioner had not shown that continuation of the case would amount to an abuse of process.

The Court rejected the request for a certificate because it saw no substantial question requiring authoritative determination by the Supreme Court.

It also rejected the oral prayer for a certificate under Article 134(1)(c), read with Article 134-A, of the Constitution.