Inherent jurisdiction cannot be exercised to quash proceedings where allegations prima facie disclose commission of cognizable offences.

The petitioner filed a petition seeking to quash FIR No. 202/2025 and the resulting criminal proceedings (Criminal Case No. 11619/2025) pending before the Chief Judicial Magistrate, Ambikapur.

The prosecution alleged that on March 22, 2025, the complainant was assaulted with a knife by a co-accused while sitting in his vehicle.

It was further alleged that when the complainant attempted to flee, the petitioner and other co-accused chased and assaulted him with iron rods and other weapons.

Following an investigation, a charge-sheet was filed under Sections 296, 351(3), 191(2), 191(3), 190, 109, 324(4), and 112 of the Bharatiya Nyaya Sanhita (BNS), 2023.

The petitioner contended the allegations were vague, the medical evidence contradicted the ocular testimony, and the complainant had previously sought a compromise.

1. Whether the High Court should exercise its inherent jurisdiction to quash an FIR and criminal proceedings when the allegations and investigative material prima facie disclose the commission of cognizable offences.

2. Whether disputed questions of fact, such as the nature of the accused's participation, medical inconsistencies, and the effect of a compromise, can be adjudicated in a quashing petition.

The Court applied the established principle that criminal proceedings should not be quashed at a preliminary stage if the uncontroverted allegations in the FIR and the material collected during investigation disclose a prima facie case.

It relied on the doctrine that the High Court, while exercising inherent jurisdiction, is not required to conduct a detailed appreciation of evidence or resolve disputed questions of fact, as these are matters for the trial court.

The proceedings were governed by the substantive provisions of the Bharatiya Nyaya Sanhita (BNS), 2023, concerning unlawful assembly, criminal intimidation, and assault.

The Court examined the FIR and the investigative material, noting that the complainant provided specific accounts of a concerted attack involving the petitioner and deadly weapons.

The bench rejected the petitioner’s arguments regarding the simple nature of the injuries and the lack of a specific overt act, categorizing these as "disputed questions of fact" that require trial-level adjudication.

The Court reasoned that the presence of eyewitness statements corroborating the prosecution's version regarding an unlawful assembly and common intention necessitated a trial.

It further held that the existence of a prima facie case prevents the use of extraordinary jurisdiction to "scuttle a legitimate prosecution" at the threshold.

The Court held that the allegations against the petitioner disclose prima facie commission of cognizable offences that require adjudication by the competent trial court.

Consequently, the Court declined to interfere with the FIR or the ongoing criminal proceedings.