Inherent jurisdiction cannot be used to evaluate evidence or conduct mini-trials during quashing proceedings.

The petitioner, a Middle School Teacher, filed a petition under Section 528 of the Bharatiya Nagrik Suraksha Sanhita (BNSS) to quash the charge-sheet and proceedings in Special Case (Corruption) No. 1 of 2026 arising from FIR No. 45 of 2025.

The prosecution alleged that the petitioner demanded a bribe of ₹2,00,000 to prevent the transfer of the complainant's wife.

The petitioner argued that he was falsely implicated due to professional animosity and that he lacked the authority to influence transfers.

He further contended that the trap was unsuccessful because the money was recovered from the complainant’s bedroom rather than his person, the phenolphthalein test was negative, and no audio-video evidence of the transaction was provided.

Conversely, the State argued that a prima facie case existed based on recorded conversations, independent witness testimony, a positive chemical examination report, and a valid prosecution sanction.

1. Whether the criminal proceedings and charge-sheet should be quashed under the inherent powers of the High Court when the allegations prima facie disclose the commission of an offence.

2. Whether factual defenses regarding non-possession of bribe money and lack of authority can be evaluated by the High Court at the stage of a quashing petition.

The Court applied Section 528 of the Bharatiya Nagrik Suraksha Sanhita, 2023 (formerly Section 482 CrPC), which grants inherent powers to the High Court to prevent abuse of the process of law, stipulating that such powers must be exercised sparingly and only when allegations, taken at face value, do not disclose an offence.

The Court further applied the principles governing Section 7 of the Prevention of Corruption Act, 1988 (as amended in 2018), which criminalizes the demand and acceptance of illegal gratification by public servants.

It adhered to the established judicial precedent that at the quashing stage, the Court cannot evaluate evidence in detail, conduct a "mini-trial," or resolve disputed questions of fact that are subject to trial.

The Court observed that the charge-sheet contained specific and categorical allegations regarding the petitioner’s demand for illegal gratification.

It noted that the prosecution’s reliance on recorded conversations, transcriptions, and trap proceedings conducted before independent witnesses established a prima facie case.

Regarding the petitioner's defenses—namely that the recovery was made from the complainant's house, that he lacked authority to influence transfers, and that there were procedural lapses in the trap (such as missing video footage)—the Court reasoned that these are matters of evidence and defense.

The Court determined that it could not embark upon a detailed inquiry into these disputed facts at this preliminary stage, as they must be tested during the trial through the examination of witnesses and evidence.

The Court dismissed the petition, holding that the grounds raised by the petitioner were matters of trial.

It clarified that the trial court must decide the case independently on its merits, uninfluenced by the observations made in this order.